North Coast Wireless Communications LLC Privacy Policy
A. GENERAL
North Coast Wireless Communications LLC (aka NCWCOM) has a firm commitment to privacy. This Privacy Policy was created to help you understand what kind of information NCWCOM collects, as well as how NCWCOM collects and uses customer information. By your use of and/or payment for the service(s), you agree to the terms of this Privacy Policy as they may be amended, modified, supplemented, or replaced with or without prior notice as provided in the section of the Customer Agreement. Except as otherwise set forth herein, the following limitations apply independently to each of the services that constitute the service(s).
As an internet service and VoIP phone service provider, NCWCOM is subject to certain federal and state laws, rules, and regulations regarding the storage, usage, and disclosure of Customer Information. INFORMATION THAT NCWCOM may collect and maintain the following customer Information regarding you and your use of the Service(s):
Your name, address(es), telephone number(s), email address(es), and other identifying information;
Billing records concerning payment of the Service Fees and other applicable charges, which may include credit card or bank account information;
Records of reported trouble or communication with respect to the Service(s) or NCWCOM Equipment;
Letters or other correspondence received from you;
Records of IP addresses that may be assigned to equipment connected to Your Service(s) from time to time;
Call detail records;
Records necessary to provide the service(s) to you, such as the information necessary to provide an on-demand program and to bill you for such program;
Information regarding your use of bandwidth, both uploading and downloading, which is necessary for NCWCOM to manage its network, including management of congestion.
B. USES FOR CUSTOMER INFORMATION; DISCLOSURE OF CUSTOMER INFORMATION
Customer information is used to provide the service(s) and collect service fees or other charges owed. NCWCOM will not intentionally disclose customer information except:
a. To the extent necessary to conduct NCWCOM’s business, (i) including the provision of the service(s) to you, including billing, maintenance or other service calls, marketing of new products that might interest you, and network management, and (ii) the collection of unpaid service fees or other charges, in which case it might be disclosed to collection agents, attorneys, or courts;
b. To respond to court orders or legal process of any kind, including any administrative agency, or to establish or exercise its legal rights or defend against legal claims, or to respond to subpoenas or warrants that are valid where issued;
c. To the extent NCWCOM believes it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities (including unauthorized reception of services), suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Customer Agreement, including this Privacy Policy, or as otherwise required or permitted by Law;
d. A governmental entity may obtain personally identifiable information concerning a subscriber pursuant to a court order only if, in the court proceeding relevant to such court order, (i) such governmental entity offers clear and convincing evidence that the subject of the information is reasonably suspected of engaging in criminal activity and that the information sought would be material evidence in the case and (ii) the subject of the information is afforded the opportunity to appear and contest such entity’s claim. However, some investigations are governed by rules which prohibit NCWCOM from informing the subscriber of any disclosure of personally identifiable information.
e. A non-government entity may obtain personally identifiable information concerning a subscriber pursuant to a court order, in which case NCWCOM is required to notify the subscriber of the court order. In certain instances, third party service providers may transmit, collect, and store personally identifiable information on NCWCOM’s behalf to provide certain features of the Service(s). These third parties are not permitted to use such personally identifiable information except as necessary to provide the relevant features.
f. NCWCOM may also combine personally identifiable information which is collected pursuant to the Customer Agreement with personally identifiable
information obtained from third parties for purpose of creating enhanced databases or business records. NCWCOM may use such databases or business records for marketing or other activities related to the provision of the various services offered by NCWCOM from time to time.
g. NCWCOM may also maintain records of research concerning subscriber satisfaction and viewing habits.
h. NCWCOM may sometimes disclose your personally identifiable information to its affiliates who work for NCWCOM, professional advisors (e.g., auditors, accountants, or attorneys), service providers and other vendors, potential business merger, acquisition or sale partners, and regulators. Any such disclosures are made in accordance with all federal, state and local laws, typically because they are necessary to conduct a legitimate business activity or because they are required by law or legal process.
C. RETENTION OF CUSTOMER INFORMATION
Generally, NCWCOM will retain customer information as long as the customer is an NCWCOM customer and for such time thereafter as may be necessary to conduct NCWCOM’s business or as otherwise required or permitted by law. Some customer information may be retained for a shorter period of time depending on storage capacity, legal requirements, and NCWCOM’s document retention policy. For example, records pertaining to a piece of NCWCOM equipment that has been replaced with new equipment may be discarded before your other customer information is discarded.
D. NO COLLECTION OF INFORMATION FROM CHILDREN
NCWCOM does not knowingly collect personally identifiable information from children under the age of thirteen (13) and does not wish to collect any such information. Federal law requires website operators who collect personal information from children under the age of thirteen (13) to first get parental consent. Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone numbers) over the internet, to NCWCOM, or to anyone else.
E. CUSTOMER FILES
Files that identify the customer personally may be inspected by the customer at NCWCOM’s local business office, by appointment, during normal business hours (Monday through Friday, 09:00 am Eastern Standard Time to 5:00 pm Eastern Standard Time). The Customer must present appropriate proof of identity (such as a driver’s license, passport, or other government-issued picture identification document) before the customer can access such files.
F. CUSTOMER’S REMEDIES
If you feel that your privacy rights have been violated by any North Coast Wireless Communications LLC action, please contact the NCWCOM customer service department in order to resolve your question or concern.
G. LIMITATIONS; PRIVACY POLICIES OF THIRD PARTIES
This Privacy Policy governs only information that is collected by North Coast Wireless Communications LLC in connection with the provision of the service(s) to you. The Website and/or the service(s) may include features of other providers or links to other websites whose privacy policies North Coast Wireless Communications LLC does not control. This Privacy Policy does not govern information which may be collected through any such third parties or their respective products or services, even if such products or services are accessed through any of the service(s) and even if such products or services are cobranded with a North Coast Wireless Communications LLC product or service. Your accessing of such features or websites and your use of such third-party products or services is governed by the privacy policy(s) (if any) of the applicable third-party(s), which may be different (in some cases significantly different) from this Privacy Policy. You are responsible for reading, understanding, and accepting the privacy policies of such other products, services, or websites.
H. SPECIAL PROVISIONS FOR TELEPHONE SERVICE
Section 702 of the Telecommunications Act requires North Coast Wireless Communications LLC to abide by certain additional privacy restrictions with respect to customer information known as CPNI. The Telecommunications Act defines this CPNI to include the following information when matched to your name, address, and/or telephone number:
Information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscribed to by any customer of NCWCOM, and that is made available to NCWCOM by the customer solely by virtue of the carrier-customer relationship;
Information contained in the bills pertaining to telephone exchange service or telephone toll service received by a customer of NCWCOM.
CPNI does not include subscriber list information, which includes any information: (i) identifying the listed names of subscribers of NCWCOM and such subscribers’ telephone numbers, addresses, or primary advertising classifications, and (ii) that NCWCOM or any of its Affiliates has published, caused to be published, or accepted for publication in any directory format.
Except as otherwise required by law, or with your approval, NCWCOM is permitted to use, disclose, or permit access to individually identifiable CPNI only in connection with its provision of: (i) the telecommunications service from which such CPNI is derived; or (ii) such services as are necessary to or used in, the provision of such telecommunications services, including the publication of directories. This restriction does not apply to the extent such CPNI is incorporated in “aggregate customer information,” which is defined as collective data that relates to a group or category of services or customers, from which individual customer identities and characteristics have been removed.
Certain exceptions to the general rules outlined above apply. NCWCOM may use, disclose, or permit access to CPNI obtained from its customers for the following:
To initiate, render, bill, and collect for telecommunications services;
To comply with caller ID rules and regulations or to otherwise transmit or display the information necessary for caller ID services;
To publish and/or distribute, or to cause to be published and/or distributed, telephone directories or directory assistance databases;
To protect the rights or property of NCWCOM, or to protect users of those services and other carriers from fraudulent, abusive, or unlawful use of, or subscription to, such services;
To otherwise comply with the law or legal process;
To provide any inbound telemarketing, referral, or administrative services to you for the duration of the call, if such call was initiated by you and you approve the use of such information to provide such services;
To provide call location information: (i) to a public safety answering point, emergency medical service provider, emergency dispatch provider, public safety, fire service, or law enforcement official, or hospital emergency or trauma care facility, in order to respond to the user’s call for emergency services; (ii) to inform the user’s legal guardian or members of the user’s immediate family of the user’s location in an emergency situation that involves the risk of death or serious physical harm; or (iii) to providers of information or database management service solely for purposes of assisting in the delivery of emergency service in response to an emergency.
These exceptions permit NCWCOM to use, disclose, or permit access to CPNI without your advance approval as it relates to NCWCOM’s provision or marketing of service offerings among the categories of service(s) to which you subscribe, subject to certain limitations. In addition, NCWCOM is required to disclose CPNI upon your affirmative written request.
I. MOBILE APPLICATION DATA PRACTICES (GENX WI-FI APP)
The GenX Wi-Fi App (“App”) is a mobile application that functions solely as a wrapper for and gateway to NCWCOM’s existing website and services. The App itself does not independently collect, store, or process personally identifiable information from users.
Information Collected by the App
The App does not directly collect or retain any personal data, device identifiers, or usage analytics from users. NCWCOM does not use the App to track users across other apps or services.However, when using the App, users may voluntarily provide information through embedded web pages (for example, logging into an account, submitting forms, or contacting support). Any such information is transmitted directly to NCWCOM’s secure web systems and is handled in accordance with this Privacy Policy as if submitted through the NCWCOM website.
Automatically Collected Information
The App itself does not implement independent tracking technologies such as cookies, software development kits (SDKs), or analytics tools.That said, the underlying website accessed through the App may automatically collect certain technical information as part of normal internet operations, including but not limited to:
• IP address
• Browser type or device type
• Pages visited and interaction dataThis information is collected and used solely through NCWCOM’s web infrastructure and is governed by the applicable sections of this Privacy Policy.
Use of Information
Because the App does not independently collect data, it does not use personal information for analytics, advertising, or profiling purposes. Any information submitted through the App is used strictly for:• Providing and maintaining services
• Account management and customer support
• Network operations and security
• Billing and service-related communicationsData Sharing and Disclosure
The App itself does not share user data with third parties. Any information submitted through the App’s web interface may be shared only as described in Section B of this Privacy Policy, including for:• Service provisioning and operations
• Legal compliance or lawful requests
• Authorized service providers acting on NCWCOM’s behalfNCWCOM does not sell personal information and does not share user data for third-party advertising purposes.
Tracking
The App does not track users across apps or websites. No third-party tracking technologies or SDKs are implemented within the App.Data Retention
The App does not store user data locally beyond what is necessary for basic functionality (such as temporary session data managed by the device or operating system). Any data submitted through the App is retained according to Section C of this Privacy Policy.Security
Although the App itself does not store data, NCWCOM uses commercially reasonable administrative, technical, and physical safeguards to protect any information transmitted through its website and services.Children’s Privacy
The App does not knowingly collect personal information from children. Any information submitted through the App is subject to the provisions outlined in Section D of this Privacy Policy.