California Consumer Privacy Act (CCPA)

California Consumer Privacy Act Notice

January 1, 2020

The California Consumer Privacy Act of 2018 (CCPA) gives California consumers the right to know what Personal Information is collected about them, and how it will be used, disclosed, and sold. The CCPA also gives California consumers the right to request access to and deletion of their personal information, and the right to request that their personal information not be sold, and the right not to be discriminated against after exercising privacy rights.

The purpose of this notice is to provide consumers with a description of our practices regarding the collection, use, disclosure, and sale of Personal Information and instructions for submitting CCPA data privacy requests.

Collection of Personal Information

We have collected the following categories of Personal Information about California consumers in the preceding 12 months. Users are asked to provide certain information when they sign up for our Services such as name, address, phone number, birth date, gender, credit card information, and email address (collectively, “personally identifiable information” or “personal information”). The personally identifiable information collected from our customers during the registration process is used to manage each customer’s account. We also seek such information to provide products and/or services that more closely reflect your preferences. In addition, we may use such personally identifiable information to improve our marketing and promotional efforts, to analyze website usage, improve our content and product offerings, and customize our website’s content, layout, and services.

How We Collect Personal Information

We collect the Personal Information identified above from the following categories of sources:

• From you and your transactions with us, such as when you request a product or service, or give us your contact information
• From our affiliates
• From others, including consumer reporting agencies and third parties that provide us with demographic and other information
• From publicly available sources

Why We Collect Personal Information

In addition to the primary purposes of collection noted above, we may generally use the categories of information noted above as follows:

• To process your orders, respond to your inquiries and fulfill your requests.
• To protect our rights and property and those of our customers.
• To respond to legal process and emergencies.
• To Develop or inform you of new products and services.
• To anonymize or aggregate personal information for various purposes like market analysis or traffic flow analysis and reporting.
• To monitor, evaluate or improve our products, Services, systems, or networks.
• To customize or personalize your experience with our Services.
• To customize personalize online advertising that provides you information about products and services of i-wireless or others that may interest you, including co-branded offers.
• To prevent or detect security incidents, fraud, and criminal activity.
• To report to consumer reporting agencies,
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may combine the Personal Information we collect for the above purposes. We will not collect additional categories of Personal Information, nor use the Personal Information collected for additional purposes, without providing you notice.

What Personal Information We Sell or Share

The CCPA defines “sale” very broadly to include sharing or disclosing of personal information with a third party for monetary or other valuable consideration. There are a number of circumstances where we are allowed to share personal information with third parties which are not considered to be a sale. For example, we may share personal information with service providers who work on our behalf if the service provider agrees not to use that personal information for other purposes. In addition, you may intentionally direct us to share information with a third-party, which is also not a sale.

Currently we have one program, which would be considered a sale under the CCPA. This program does not directly identify you but allows a third party to aggregate the data and issue de-identified marketing and analytics reports. If you do not wish for us to use your information to produce de-identified and aggregated data sets in the reports we share with third parties, you may opt out at any time.

We may share the Personal Information identified in the chart above with the following categories of third parties:

• Service providers - We may share personal information with third parties who perform services on our behalf. Credit bureaus and similar regulated entities, that we use as part of processing your application and determining eligibility for our services, may incorporate the personal information we submit as part of our inquiry into their databases. They may use the personal information that we submit for other purposes consistent with applicable law.
• Relationship, Discount, and Reward Programs - We may share limited personal information (e.g., name, address, telephone number, account status/active or inactive, membership number) with non-i-wireless entities when you sign up for a discount or reward program, including when you sign up for a service discount through the i-wireless Discount Program, for eligibility verification, fulfillment, and administrative purposes.
• Third Party Verification Services - We may share limited personal information (e.g., address, phone number) with non-i-wireless entities to assist with identity verification, and to prevent fraud and identity theft.
• Business Transfers Personal information about you may be disclosed as part of any merger, acquisition, sale of company assets or transition of service to another provider. In the unlikely event of an insolvency, bankruptcy or receivership, personal information may also be transferred as a business asset.
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Your Rights under the CCPA 

• You have the right to request that we disclose what personal information we collect, use, disclose, and sell.
• You have the right to request deletion of any personal information about you that we have collected from you.
• You have a right to opt-out of the sale of your personal information.
• You have a right not to receive discriminatory treatment by us for your exercise of your privacy rights and we would not do so.

How to Submit a Data Privacy Request

To submit a request for access, deletion, or opt-out, please complete the online request form by visiting https://ccpa.iwirelesshome.com/ or you can call 1-866-594-3644 to speak with a customer support specialist or e-mail ccpa@iwirelesshome.com.

Verification of Your Identity

To process your request for access or deletion, we must be able to verify your identity to a reasonable degree of certainty. In order to do so, you must provide the required identifying information when completing the online request form or making a request through one of our customer service agents. We will ask you to provide your contact information and an additional identifier based on your relationship with us. Before we process your request, we will match these data points with data points we currently maintain to verify your identity and your relationship with us.

Responding to Your Requests

Please note that we may not be required to delete information under certain circumstances. For example, the CCPA includes exemptions that provide that we do not have to delete data that for example, is necessary to complete a transaction, detect security incidents, or for certain other internal purposes.

You can designate an authorized agent to make a request to know, delete, or opt-out on your behalf. When you use an authorized agent to submit a request for access or deletion, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

Questions or Concerns

If you have any questions about or complaints that concern this Privacy Policy please call Access Wireless Customer Care at 1-866-594-3644 or e-mail ccpa@iwirelesshome.com. If you prefer, you also may write us at Office of Privacy - Legal Department, Access Wireless, One Levee Way Suite 3116, Newport, KY 41071.