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Privacy Policy
Enterprise PCS Privacy Policy
Effective date: August 1, 2008
PRIVACY POLICY
Enterprise PCS believes that when you use any Enterprise PCS product or service, you should understand when and how personal information is collected, used, disclosed and protected. That's why we have provided you with this Privacy Policy (the "Policy").
The Policy applies to all Enterprise PCS traffic originated in the United States, including those providing retail and wholesale wireline, wireless and Internet services. International transactions are protected under applicable laws in the various nations where the transactions take place. The Privacy Policy applies to visits to or transactions with Enterprise PCS Websites such as www.EnterprisePCS.com as well as to Internet services accessed through Enterprise PCS wireless devices, Internet services, wireless voice services, and wireline voice products. Enterprise PCS CUSTOMER INFORMATION PRIVACY PRINCIPLES
This section explains the five principles of the Enterprise PCS Privacy Policy.
Enterprise PCS protects the privacy of its local, long distance and wireless customers consistent with applicable law, such as the Federal Communications Commissions (FCC's) regulations that govern Customer Proprietary Network Information (CPNI).
CPNI is information Enterprise PCS obtains or creates when it provides wireline or mobile wireless telecommunications services to a customer. CPNI includes the types of services purchased, how the services are used, and the billing detail for those services. CPNI includes, for example, the number and type of lines, class of service, current charges, calling plans, call detail records, and bill summary. The FCC does not deem a customer's name, service address or telephone number to be CPNI, consistent with the publication of this information in telephone directories.
Enterprise PCS does not disclose CPNI outside Enterprise PCS or its authorized agents without customer consent except as required or allowed by law. When Enterprise PCS uses agents, contractors, or other companies to perform services on its behalf, Enterprise PCS requires that they protect CPNI or other sensitive personal information consistent with these Privacy Principles.
In the context of these Privacy Principles, subscriber information is information that is directly associated with a customer such as name, address, telephone number, e-mail address, activities and preferences. Nonpublic information generally means a subset of information, which is sensitive and not publicly available, such as credit card number, social security number, and bank account information. Publicly available information is information that is typically available from governmental records, telephone and other public directories, widely distributed media such as newspapers and radio, and from companies that provide demographic or marketing materials to others as a part of their business. Publicly available information includes contact information, such as name, address, telephone number, email address, activities, and preferences.
These principles apply generally within Enterprise PCS.
1.Enterprise PCS creates, obtains uses your subscriber information to provide you the products and services of Enterprise PCS, and to present you with product and service offerings that we believe may interest you.
2.Enterprise PCS provides its customers opportunities to control whether Enterprise PCS (a) uses Customer Proprietary Network Information (CPNI) to sell them different categories of communications-related products and services, as well as non-communications related products and services, and (b) contacts them with offers on products and services.
3.Enterprise PCS does not disclose CPNI and other nonpublic personal information (such as credit card numbers), without your consent or direction, except to business partners involved in providing Enterprise PCS service to customers, or as required or allowed by law. When Enterprise PCS discloses CPNI or other nonpublic personal information to business partners, the Enterprise PCS contract with the business partner protects the nonpublic personal information from uses outside of those necessary to assist in providing Enterprise PCS service. Enterprise PCS will disclose CPNI and other nonpublic customer information as specifically directed by customers, such as when a customer has made another company the agent of the customer for purposes of arranging service.
4.Enterprise PCS endeavors to make CPNI and other nonpublic personal information contained in its records available to customers through its customer service representatives and through applicable web interfaces.
These Principles explain Enterprise PCS's commitment to protecting the privacy of nonpublic subscriber information. In order to serve its subscribers, Enterprise PCS must develop, obtain and use sensitive nonpublic personal information and Enterprise PCS recognizes that its subscribers are rightfully concerned that their information be used for only appropriate purposes and that their nonpublic information be protected from inappropriate use or disclosure. Enterprise PCS's goal is simple: to balance the interests and concerns of our subscribers dealing with privacy of their information with their interest in receiving quality service and information about useful new products.
INFORMATION WE COLLECT
We collect information about users of our products or services in the normal course of our business. This is how we know where to send you a bill for service, for example, or to ensure you are qualified for the selected service plan or plans, or to identify you when you call for customer assistance. The information we collect also helps us improve and keep you informed of new services and products.
Subscriber information is information that is directly associated with a specific person such as name, address, telephone number, e-mail address, activities, and personal preferences. Our definition of such information does not include de-identified information. This is information that we collect about users, a category of services, or customers and from which personal and specific customer information has been removed. This data helps us understand trends and customer needs so that we can better consider new services or tailor existing services to customer desires. De-identified data also might be purchased by or shared with a third party: for example, one interested in locating a business in a particular part of town.
For our business and government customers, our customer is the business or government entity purchasing the service or product for its employees or other authorized users. If you receive certain pricing, terms or other benefits through a business or government customer's agreement with us, this Policy governs your personal information. If the business or government customer requests information about your account or usage of the services, we may share such information. For example, we may need to provide such information to determine your continued eligibility to receive the services under an agreement or the law, such as in the case of priority access.
Here are some examples of the types of information we collect and when we collect it. You should refer to the rest of this Policy to see how we use, disclose and protect that information:
Information Given to us by our Customers: We collect personal information when Enterprise PCS products are purchased or Enterprise PCS services are used. When you purchase phones, accessories, or services, we may request information about our customers and/or subscribers, such as the following types of information:
Name
Shipping and/or billing address
Credit card number or account number
Residential or business phone or fax number
Email address
Date of birth
Social Security Number
Driver's license number
For corporate accounts, we may ask you for one or more of the following types of information:
Federal Tax ID
Company name
Other information your employer may ask us to collect, such as purchase order number, employee number, and the like
When you register for any of our services (such as our wireless, wireline, Internet, integrated voice response, or customer service), you may provide us with a user name, password, and/or response to a secret question.
You may provide information in response to surveys we conduct online or offline. If this information is connected directly to your identity, it is personal information under this Policy. Otherwise, it may be used in de-identified (or aggregate) form as described below.
You may also provide us with personal information whenever you interact with us, such as when you ask for customer service or technical assistance, or when you submit a job application.
You may have heard about "customer proprietary network information" or "CPNI." In general, this is information about your phone usage, which is a special category of personal information. A special section below explains your CPNI rights in detail.
Automatically Collected Information: We automatically receive certain types of information whenever you interact with us through our Website. For example, when you visit a or www.Enterprise PCS.com Website, our systems automatically collect your IP address, the type of browser you use, and the Website from which your visit originated. When you browse the wireless web or use our high-speed Internet services, our systems log the websites you visit. Similarly, our wireless communications systems know when your wireless device is turned on and approximately where it is located, what device you are using, and how you are using it.
Information from Other Sources: We may obtain information about you from outside sources and add it to or combine it with your personal or company information. For example, we may receive credit information when service is initially subscribed to. We also may use commercially available marketing information from third parties to help us better serve you or inform you about products or services that we think will be of interest to you. We sometimes receive updated delivery and address information from our shippers or other sources so that we can correct our records and deliver your next purchase or communication more easily. We often receive information from the dealer from whom you purchase your wireless phone or device prior to initiating service with us. We may receive personal information from those application service providers that bring you services through the Enterprise PCS network and with whom you subscribe. (You should always check the privacy policies of other service providers to ensure you understand your privacy choices before subscribing to any service.) And, we may purchase lists containing your personal information (postal address, phone number(s), and email address(es) from third parties for advertising purposes. Information we purchase from others is not protected as non-public personal information under this Policy.
CHILDREN'S ONLINE PRIVACY
Insofar as our products and services may be used by children under 13 without Enterprise PCS's knowledge and, if that happens, any information collected from the usage will appear to be the personal information of the actual adult subscriber and treated as such under this Policy.
Enterprise PCS services are not intended for children and Enterprise PCS does not knowingly collect personal or usage information from children under the age of 13.
USE OF PERSONAL INFORMATION
Enterprise PCS uses the information you provide for the purpose it was provided in the normal course of our business and to provide you with marketing communications, as detailed below. The following explains in more detail how we use personal information.
Internal Business Use. Your personal information is used in many aspects of our business operations. We use personal information to provide you the services you request, to properly identify you when you contact us, to bill and collect for services, to ensure your creditworthiness for continued service, to determine appropriate state and local payment of taxes, to protect our rights or property, or to enforce the terms of any agreements or terms of service. We use personal information to communicate with you about your account or other matters, our services or products you use, or to respond to your requests.
Marketing Communications. We use personal information to inform you about new products and services. We may contact you at your wireless, residential or business phone numbers, by email or text message, fax or by automated voice messaging and by direct mail. If you are a Enterprise PCS subscriber and want to change your preferences for receiving marketing communications, you may call us at the customer service number shown on your bill or send an email to customercare@EnterprisePCS.com. While you may choose not to receive email or telephone marketing information from us, you will continue to receive invoices, customer service-related notifications, technical or network-related notifications and similar information from us electronically or otherwise.
Do-Not-Call Policy. Enterprise PCS maintains its own "do-not-call" list to enable subscribers and potential customers to prevent future telephone marketing calls to any phone number. During a telemarketing call, you may be asked to contact Enterprise PCS Customer Care at a toll-free number given to you during the call if you wish to register a do-not-call request. You also may register your request by sending an email to customercare@EnterprisePCS.com. Enterprise PCS will promptly record your preference, although you should allow up to thirty (30) days for your number to be removed from any Enterprise PCS sales campaign then underway. Any do-not-call request associated with a particular number will be respected by Enterprise PCS for a minimum period of five (5) years, or longer if required by law, and two (2) years for our business customers. In the event that you change your number, you should contact Enterprise PCS to remove your old telephone number and add your new number to Enterprise PCS's do-not-call list, if you want to maintain your do-not-call preference. Also, please remember, you still will receive customer service or account-related calls from Enterprise PCS. Enterprise PCS checks the telephone numbers of residential non-subscribers on the national and state do-not-call registries and does not call persons who have put their numbers on those registries, except as otherwise permitted by law. For example, Enterprise PCS may contact former customers or others with whom the company has an established business relationship unless you are listed on our internal do-not-call list.
Wireless Commercial Mobile Messages. Enterprise PCS may send short-message (SMS) advertisements to your wireless device, but it provides you with the opportunity to opt out of such messages in the future. Enterprise PCS does not send mobile-message (i.e., text messages as opposed to SMS messages) advertisements to your wireless device without your prior consent. If you have consented to receive such commercial mobile messages from us, you may change your preference at any time by sending an email to customercare@EnterprisePCS.com or by calling our Customer Care representatives at the number shown on your bill. Remember, you will still receive customer-service or account-related messages from Enterprise PCS. Finally, if you opted in to receive commercial mobile messages from third parties, you must opt out with them directly. Enterprise PCS is not responsible for commercial mobile messages sent by unauthorized third parties, including those who purport to be selling Enterprise PCS products or services. Enterprise PCS maintains an anti-spam filter in an effort to block as many unwanted messages as possible but inevitably, some unwanted messages will get through the filter. You may report such messages to Customer Care.
Email. Enterprise PCS maintains a "do-not-email" list for those recipients of commercial email messages from Enterprise PCS who have opted out of such communications. You may opt out of email by sending an email to customercare@EnterprisePCS.com, calling our Customer Care representatives at the number shown on your bill, or, by following the opt-out instructions in the email for up to 30 days after receipt. Enterprise PCS will honor your request within thirty (30) business days. Remember, you may still receive customer-service or account-related messages from Enterprise PCS. Enterprise PCS is not responsible for commercial email messages sent by unauthorized third parties, including those who purport to be selling Enterprise PCS products or services but do not have our permission.
Enterprise PCS or its agents may store e-mail messages for a brief period of time. Enterprise PCS or its partners may, without legal process, access and disclose the messages to protect both an individual during emergencies, or Enterprise PCS from unlawful or fraudulent use of its services. Additionally, you may store some information, such as pictures, for longer periods of time. Enterprise PCS may access and disclose such media without legal process to protect an individual during emergencies, or Enterprise PCS from unlawful or fraudulent use of its services.
Direct Mail. Personal accountholders may request not to receive promotional direct mail from us by sending an email to customercare@EnterprisePCS.com or calling our Customer Care representatives at the number shown on your bill. Of course, you will still receive account-related information (such as your invoice) by mail.
Facsimile. Enterprise PCS does not send commercial information by fax, unless you request such information to be sent by fax. You may email our Office of Privacy at customercare@EnterprisePCS.com or call our Customer Care representatives at the number shown on your bill if you believe you have received an unwanted fax from Enterprise PCS. Our business and government customers should contact their account representative. Enterprise PCS is not responsible for commercial fax messages sent by unauthorized third parties, including those who purport to be selling Enterprise PCS products or services but who do not have our permission.
Customer Proprietary Network Information ("CPNI"). There are special rules related to the access, use and disclosure of customer proprietary network information or "CPNI." This Policy incorporates those rules throughout. You have a right, and Enterprise PCS has a duty, under the law, to ensure the confidentiality of CPNI. In other circumstances, we may also disclose your CPNI as permitted by law.
Your name, address and phone number are not CPNI, but otherwise are covered by this Policy.
We may use your CPNI to market additional communications and data products and services similar to the types you currently purchase from us. For example, a wireless customer can be marketed wireless Internet access, new messaging products, location-based services, interactive services, or photo or message storage, handsets or related equipment. With your opt-out permission we may also market additional products and services we and our partners sell. For example, we may sell long distance to you as a wireless customer. We may also use CPNI to contact former customers when permitted by law. And, to provide your service, we may use and disclose CPNI to our agents, affiliates, joint venture partners and independent contractors, but we restrict their use and limit disclosure of CPNI for purposes or providing service to you or to market products and services as previously described. We will also prohibit the third party from further disclosing the CPNI except as required by law and require the third party to implement safeguards to protect the confidentiality of the CPNI. If you are a new customer of Enterprise PCS, you will receive a notice of your CPNI rights and further information on this topic from Enterprise PCS. When you have not already given Enterprise PCS your permission to use CPNI for marketing purposes, Enterprise PCS will give you 33 days after soliciting your consent before using your CPNI and Enterprise PCS will follow your directions if you choose not to provide your consent.
Enterprise PCS and its employees shall take reasonable measures to discover and protect against attempts to gain unauthorized access to CPNI. All employees must properly authenticate a customer prior to disclosing CPNI during customer-initiated calls, online account access, or in-store visits.
�Call detail information� means any information pertaining to specific calls, including numbers called to/from, time, duration, or location of calls. Amount of minutes used or remaining minutes of use are not call detail records. When a customer calls a Enterprise PCS representative or authorized dealer, the Enterprise PCS representatives may only disclose call detail information under the following circumstances: (1) If the customer gives his or her password, established online or through the customer�s account. The password may not use readily available biographical information such as addresses, SSN, or driver�s license numbers. The representative may refer the customer to the Enterprise PCS website to establish a password, or call the customer back on the Enterprise PCS Wireless number associated with the requested records to establish a password for future call detail requests; (2) If the customer does not have a password, call detail information may be disclosed if the representative sends the information to the address on the customer account or by calling the customer back on the Enterprise PCS Wireless number associated with the requested records. Representatives may not call a different number to disclose information, and may not send the call detail records to any other address than that on the account; and (3) If the customer is able to provide call detail information to the representative, then the representative may discuss the information provided by the customer.
Online account access via our website shall require online authentication prior to disclosing CPNI. Such authentication shall not use account information or readily available biographical information such as addresses, SSN, mother�s maiden name or driver�s license numbers.
In the event a Customer forgets or loses his or her password, a back-up method may be used to authenticate a customer. The back-up method may not prompt the customer for account number or readily available biographical information.
Retail sales associates and Dealers may disclose CPNI to a customer, provided the customer presents a valid photo ID matching the customer�s account information.
Enterprise PCS may utilize other authentication procedures not described here for services provided to businesses, provided that the account has a dedicated account representative, and that the account has a contract specifically addressing Enterprise PCS protection of CPNI.
Enterprise PCS shall notify the customer via voicemail, text message, or US mail, anytime a customer�s password, response to back-up question, online account information, or address of record is created or changed. This notification is not required when the new customer initiates service, but is required when a current customer obtains a password via the Enterprise PCS website.
Enterprise PCS has designated a CPNI Compliance Officer who is responsible for: (1) communicating with the Company�s attorneys and/or consultants regarding CPNI responsibilities, requirements and restrictions; (2) supervising the training of Company employees and agents who use or have access to CPNI; (3) supervising the use, disclosure, distribution or access to the Company�s CPNI by independent contractors and joint venture partners; (4) maintaining records regarding the use of CPNI in marketing campaigns; and (5) receiving, reviewing and resolving questions or issues regarding use, disclosure, distribution or provision of access to CPNI.
DISCLOSURE OF PERSONAL INFORMATION
This section of the Policy explains when personal information may be disclosed.
Vendors. We may share personal information with a third party to complete a transaction you have requested or to perform a service on our behalf. When the third party acts solely on our behalf, Enterprise PCS does not allow it to use your information for other purposes. For example, our vendors process and print your billing statement on our behalf. They can only use the personal information we give them to produce the billing statement.
Your Disclosures to Third Parties Through Our Services. You may also want to take advantage of services and products offered by other companies through our wireless services. In those cases, you will be providing information to those companies directly, and information about you received by those third parties will be governed by their privacy policies, not this Policy. For example, if you are roaming on the network of another carrier, information about your usage and the numbers you dial will be available to the carrier providing the service. Also, as another example, if you purchase something using our mobile Internet service, you will be disclosing personal information directly to the company facilitating the transaction, a merchant bank and the merchant. And, if you bought your wireless device from a third party retailer or dealer, both they and Enterprise PCS will have personal information as a result of the transaction. Whenever third parties have a role in any such transaction, you should review their privacy policies as well.
Contests and Promotions. From time to time you may be able to participate in contests, giveaways or other similar promotions we sponsor. Participation may require sharing your personal information with a sponsor of the contest, giveaway, or promotion, and you should check the rules to determine how your information will be used and shared with others. Some states also require that contest winners be filed with a state agency.
Business Transfers. Information about our users, including personal information, may be disclosed as part of any merger, acquisition, sale of company assets or transition of service to another provider, as well as in the unlikely event of an insolvency, bankruptcy or receivership in which personal information would be transferred as one of the business assets of the company.
Protection of Enterprise PCS and Others. We disclose personal information when we believe release is appropriate to comply with the law (e.g., legal process, E911 information); to enforce or apply our customer agreements; to initiate, render, bill, and collect for services; protect our rights or property, or those of users of our services; to protect other service providers from fraudulent, abusive, or unlawful use of, or subscription to, such services; facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government requirement, or eligibility for government benefits; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.
PRESENCE, LOCATION AND TRACKING INFORMATION
To make wireless communications possible, our network knows the general location of your phone or wireless device whenever it is turned on. Your wireless device sends out a periodic signal to the nearest radio tower/cell site so that our network will know where to route an incoming communication and how to properly bill for the service. This is necessary to make wireless communications possible. Location information derived from providing our voice service, in addition to being covered by this Policy, is CPNI and is protected as described above.
If you dial 9-1-1 for emergency services, we provide your call location to a public safety answering point, emergency medical service provider or emergency dispatch provider, public safety, fire service, or law enforcement official, or hospital emergency or trauma care facility. The law also permits us to disclose the call location of a device on our network without a user's consent (1) to a user's legal guardian or members of a user's immediate family in an emergency situation that involves the risk of death or serious physical harm, (2) to database management services or information providers solely to assist in delivering emergency services, (3) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires or justifies disclosure of a device's location on the network without delay, and (4) in "aggregate" form. Aggregate data is collective data that relates to a group or category of services or customers, from which individual customer identities and characteristics have been removed.
We offer wireless location-based applications that use your wireless network location to provide the service you request. For example, you may choose to subscribe to a service that provides driving directions on your wireless device. Please review the terms and conditions for each service for additional information about how the location information will be used or disclosed. It is important to note, if you let others use location-based services to which you've subscribed as the account holder (or if you let others use your handset if such handset has location tracking capabilities), it is your responsibility to inform that user that his or her location may be tracked.
Your wireless Internet service may also be personalized using your zip code or other location identifiers. We use this information to serve you relevant content, and we treat the information like any other personal information under this Policy.
COOKIES AND WEB BEACONS ON THE WEBSITE
Cookies are small files placed on your computer's hard drive by a Website when you visit. These files identify your computer and record your preferences and other data about your visit so that when you return to the site, the site knows who you are and can personalize your visit. For example, cookies enable a Website shopping cart to function so that you only have to check out once. Consequently, cookies are often tied to the use of personally identifiable information while using our site and some functionality may be lost if you choose not to accept the use of cookies.
In general, we use cookies to collect information so that we can determine how to improve our site by seeing which areas, features and products are most popular; to personalize the site and make recommendations based on products you have liked in the past as well as to improve the site experience; and to complete transactions you have requested. Advertisers that serve ads on our site may also use their own cookies. Such outside cookies are governed by the privacy policies of the entities placing the ads, and are not subject to this Policy.
We also use a session-based cookie that maintains a user's session for continuity of navigation while viewing the site. After closing the browser the session cookie simply terminates.
With wireless Internet service, cookies are also used by our suppliers and third party vendors to facilitate the various services and information offered. Depending on the phone or device being used, cookies may be stored locally on the phone or device, or on servers operated by Enterprise PCS. This Internet cookie-like functionality is in place for the same reasons and designed for the same purposes as cookies placed on your computer when interacting with Internet Websites. Each site you visit while using the wireless Internet service is controlled by a separate company and their individual privacy policies will govern information they receive automatically from the cookie or information you voluntarily provide.
A Web beacon, also known as a Web bug, is a small, graphic image on a Web page, Web-based document or in an e-mail message that is designed to allow the site owner or a third party to monitor the address and other information of the site viewing the item. Web beacons are often invisible to the user because they are typically very small (only 1-by-1 pixel) and the same color as the background of the Web page, document or e-mail message. Web beacons are represented as HTML IMG tags in the Web page; users can click on "view profiles" of the Web page to see whether the page is using a Web beacon. Web beacons collect the IP address of the computer to which the Web beacon is sent, the URL of the page from which the Web beacon comes, and the time it was viewed. Web beacons can also be linked to personal information.
Enterprise PCS may place Web beacons on its site in conjunction with cookies to monitor how visitors are navigating and/or interacting with the site. Enterprise PCS does not link Web beacons to a visitor's personal information and generally does not permit third parties, other than those working on our behalf, to place them on our site.
Enterprise PCS PLACEMENT OF BANNER ADS ON OTHER WEBSITES
Enterprise PCS may use third-party advertising companies to place advertisements about our products and services on other Websites. The advertising companies may use cookies and other technology such as Web beacons or tagging to measure the effectiveness of our ads. To measure advertising effectiveness and offer selective ad content, the advertising companies may use anonymous information about your visits to our and other Websites. The use of such cookies is subject to the advertising company's privacy policy, not the policy of Enterprise PCS.
NETWORK AND INFORMATION SECURITY
We maintain a variety of physical, electronic, and procedural safeguards to guard your personal information. For example, we take a variety of steps to protect against unauthorized access to our systems that store personal information such as policies limiting access to those systems to authorized personnel.
When you are ordering new services or products through the Enterprise PCS Website, we employ standard security measures to assure the security of your ordering information. You should be aware that Enterprise PCS has no control over the security of other sites on the Internet you might visit, interact with, or from which you buy products or services.
You should keep your user name, password or other access information safe and confidential to protect against unauthorized access to your account information and services. And you must adopt passwords that others may not guess easily.
RETENTION OF INFORMATION
Enterprise PCS retains all of the information it collects under this Policy for as long as there is a business need for it. In addition, we have a record retention policy that generally implements the broad range of regulatory requirements imposed on service providers for recordkeeping.
CHECKING ACCOUNT INFORMATION FOR ACCURACY AND ACCESSING YOUR REGISTRATION PROFILE
To change your contact, phone, account or e-mail preference information please contact: customercare@EnterprisePCS.com.
UPDATING THIS POLICY
enterprisepcs will update this Policy if our practices change or if the law requires changes to it. If at any point we decide to use personally identifiable information in a manner that is materially different from what was stated at the time it was collected, we will notify you via posting on this page for 30 days before the material change is made and give you an opportunity to opt out of the proposed use at any time. CONTACTING US If you have any questions about, or complaints that concern, this Policy, please visit Customer Care Online or email us at customercare@enterprisepcs.com or call Customer Care at the number shown on your bill. If you prefer, you also may write us at Privacy Department, 11400 SE 8th St., Bellevue, WA 98004. Our representatives will respond to your inquiries or help resolve any dispute concerning this Online Privacy Policy.
Effective date: August 1, 2008
PRIVACY POLICY
Enterprise PCS believes that when you use any Enterprise PCS product or service, you should understand when and how personal information is collected, used, disclosed and protected. That's why we have provided you with this Privacy Policy (the "Policy").
The Policy applies to all Enterprise PCS traffic originated in the United States, including those providing retail and wholesale wireline, wireless and Internet services. International transactions are protected under applicable laws in the various nations where the transactions take place. The Privacy Policy applies to visits to or transactions with Enterprise PCS Websites such as www.EnterprisePCS.com as well as to Internet services accessed through Enterprise PCS wireless devices, Internet services, wireless voice services, and wireline voice products. Enterprise PCS CUSTOMER INFORMATION PRIVACY PRINCIPLES
This section explains the five principles of the Enterprise PCS Privacy Policy.
Enterprise PCS protects the privacy of its local, long distance and wireless customers consistent with applicable law, such as the Federal Communications Commissions (FCC's) regulations that govern Customer Proprietary Network Information (CPNI).
CPNI is information Enterprise PCS obtains or creates when it provides wireline or mobile wireless telecommunications services to a customer. CPNI includes the types of services purchased, how the services are used, and the billing detail for those services. CPNI includes, for example, the number and type of lines, class of service, current charges, calling plans, call detail records, and bill summary. The FCC does not deem a customer's name, service address or telephone number to be CPNI, consistent with the publication of this information in telephone directories.
Enterprise PCS does not disclose CPNI outside Enterprise PCS or its authorized agents without customer consent except as required or allowed by law. When Enterprise PCS uses agents, contractors, or other companies to perform services on its behalf, Enterprise PCS requires that they protect CPNI or other sensitive personal information consistent with these Privacy Principles.
In the context of these Privacy Principles, subscriber information is information that is directly associated with a customer such as name, address, telephone number, e-mail address, activities and preferences. Nonpublic information generally means a subset of information, which is sensitive and not publicly available, such as credit card number, social security number, and bank account information. Publicly available information is information that is typically available from governmental records, telephone and other public directories, widely distributed media such as newspapers and radio, and from companies that provide demographic or marketing materials to others as a part of their business. Publicly available information includes contact information, such as name, address, telephone number, email address, activities, and preferences.
These principles apply generally within Enterprise PCS.
1.Enterprise PCS creates, obtains uses your subscriber information to provide you the products and services of Enterprise PCS, and to present you with product and service offerings that we believe may interest you.
2.Enterprise PCS provides its customers opportunities to control whether Enterprise PCS (a) uses Customer Proprietary Network Information (CPNI) to sell them different categories of communications-related products and services, as well as non-communications related products and services, and (b) contacts them with offers on products and services.
3.Enterprise PCS does not disclose CPNI and other nonpublic personal information (such as credit card numbers), without your consent or direction, except to business partners involved in providing Enterprise PCS service to customers, or as required or allowed by law. When Enterprise PCS discloses CPNI or other nonpublic personal information to business partners, the Enterprise PCS contract with the business partner protects the nonpublic personal information from uses outside of those necessary to assist in providing Enterprise PCS service. Enterprise PCS will disclose CPNI and other nonpublic customer information as specifically directed by customers, such as when a customer has made another company the agent of the customer for purposes of arranging service.
4.Enterprise PCS endeavors to make CPNI and other nonpublic personal information contained in its records available to customers through its customer service representatives and through applicable web interfaces.
These Principles explain Enterprise PCS's commitment to protecting the privacy of nonpublic subscriber information. In order to serve its subscribers, Enterprise PCS must develop, obtain and use sensitive nonpublic personal information and Enterprise PCS recognizes that its subscribers are rightfully concerned that their information be used for only appropriate purposes and that their nonpublic information be protected from inappropriate use or disclosure. Enterprise PCS's goal is simple: to balance the interests and concerns of our subscribers dealing with privacy of their information with their interest in receiving quality service and information about useful new products.
INFORMATION WE COLLECT
We collect information about users of our products or services in the normal course of our business. This is how we know where to send you a bill for service, for example, or to ensure you are qualified for the selected service plan or plans, or to identify you when you call for customer assistance. The information we collect also helps us improve and keep you informed of new services and products.
Subscriber information is information that is directly associated with a specific person such as name, address, telephone number, e-mail address, activities, and personal preferences. Our definition of such information does not include de-identified information. This is information that we collect about users, a category of services, or customers and from which personal and specific customer information has been removed. This data helps us understand trends and customer needs so that we can better consider new services or tailor existing services to customer desires. De-identified data also might be purchased by or shared with a third party: for example, one interested in locating a business in a particular part of town.
For our business and government customers, our customer is the business or government entity purchasing the service or product for its employees or other authorized users. If you receive certain pricing, terms or other benefits through a business or government customer's agreement with us, this Policy governs your personal information. If the business or government customer requests information about your account or usage of the services, we may share such information. For example, we may need to provide such information to determine your continued eligibility to receive the services under an agreement or the law, such as in the case of priority access.
Here are some examples of the types of information we collect and when we collect it. You should refer to the rest of this Policy to see how we use, disclose and protect that information:
Information Given to us by our Customers: We collect personal information when Enterprise PCS products are purchased or Enterprise PCS services are used. When you purchase phones, accessories, or services, we may request information about our customers and/or subscribers, such as the following types of information:
Name
Shipping and/or billing address
Credit card number or account number
Residential or business phone or fax number
Email address
Date of birth
Social Security Number
Driver's license number
For corporate accounts, we may ask you for one or more of the following types of information:
Federal Tax ID
Company name
Other information your employer may ask us to collect, such as purchase order number, employee number, and the like
When you register for any of our services (such as our wireless, wireline, Internet, integrated voice response, or customer service), you may provide us with a user name, password, and/or response to a secret question.
You may provide information in response to surveys we conduct online or offline. If this information is connected directly to your identity, it is personal information under this Policy. Otherwise, it may be used in de-identified (or aggregate) form as described below.
You may also provide us with personal information whenever you interact with us, such as when you ask for customer service or technical assistance, or when you submit a job application.
You may have heard about "customer proprietary network information" or "CPNI." In general, this is information about your phone usage, which is a special category of personal information. A special section below explains your CPNI rights in detail.
Automatically Collected Information: We automatically receive certain types of information whenever you interact with us through our Website. For example, when you visit a or www.Enterprise PCS.com Website, our systems automatically collect your IP address, the type of browser you use, and the Website from which your visit originated. When you browse the wireless web or use our high-speed Internet services, our systems log the websites you visit. Similarly, our wireless communications systems know when your wireless device is turned on and approximately where it is located, what device you are using, and how you are using it.
Information from Other Sources: We may obtain information about you from outside sources and add it to or combine it with your personal or company information. For example, we may receive credit information when service is initially subscribed to. We also may use commercially available marketing information from third parties to help us better serve you or inform you about products or services that we think will be of interest to you. We sometimes receive updated delivery and address information from our shippers or other sources so that we can correct our records and deliver your next purchase or communication more easily. We often receive information from the dealer from whom you purchase your wireless phone or device prior to initiating service with us. We may receive personal information from those application service providers that bring you services through the Enterprise PCS network and with whom you subscribe. (You should always check the privacy policies of other service providers to ensure you understand your privacy choices before subscribing to any service.) And, we may purchase lists containing your personal information (postal address, phone number(s), and email address(es) from third parties for advertising purposes. Information we purchase from others is not protected as non-public personal information under this Policy.
CHILDREN'S ONLINE PRIVACY
Insofar as our products and services may be used by children under 13 without Enterprise PCS's knowledge and, if that happens, any information collected from the usage will appear to be the personal information of the actual adult subscriber and treated as such under this Policy.
Enterprise PCS services are not intended for children and Enterprise PCS does not knowingly collect personal or usage information from children under the age of 13.
USE OF PERSONAL INFORMATION
Enterprise PCS uses the information you provide for the purpose it was provided in the normal course of our business and to provide you with marketing communications, as detailed below. The following explains in more detail how we use personal information.
Internal Business Use. Your personal information is used in many aspects of our business operations. We use personal information to provide you the services you request, to properly identify you when you contact us, to bill and collect for services, to ensure your creditworthiness for continued service, to determine appropriate state and local payment of taxes, to protect our rights or property, or to enforce the terms of any agreements or terms of service. We use personal information to communicate with you about your account or other matters, our services or products you use, or to respond to your requests.
Marketing Communications. We use personal information to inform you about new products and services. We may contact you at your wireless, residential or business phone numbers, by email or text message, fax or by automated voice messaging and by direct mail. If you are a Enterprise PCS subscriber and want to change your preferences for receiving marketing communications, you may call us at the customer service number shown on your bill or send an email to customercare@EnterprisePCS.com. While you may choose not to receive email or telephone marketing information from us, you will continue to receive invoices, customer service-related notifications, technical or network-related notifications and similar information from us electronically or otherwise.
Do-Not-Call Policy. Enterprise PCS maintains its own "do-not-call" list to enable subscribers and potential customers to prevent future telephone marketing calls to any phone number. During a telemarketing call, you may be asked to contact Enterprise PCS Customer Care at a toll-free number given to you during the call if you wish to register a do-not-call request. You also may register your request by sending an email to customercare@EnterprisePCS.com. Enterprise PCS will promptly record your preference, although you should allow up to thirty (30) days for your number to be removed from any Enterprise PCS sales campaign then underway. Any do-not-call request associated with a particular number will be respected by Enterprise PCS for a minimum period of five (5) years, or longer if required by law, and two (2) years for our business customers. In the event that you change your number, you should contact Enterprise PCS to remove your old telephone number and add your new number to Enterprise PCS's do-not-call list, if you want to maintain your do-not-call preference. Also, please remember, you still will receive customer service or account-related calls from Enterprise PCS. Enterprise PCS checks the telephone numbers of residential non-subscribers on the national and state do-not-call registries and does not call persons who have put their numbers on those registries, except as otherwise permitted by law. For example, Enterprise PCS may contact former customers or others with whom the company has an established business relationship unless you are listed on our internal do-not-call list.
Wireless Commercial Mobile Messages. Enterprise PCS may send short-message (SMS) advertisements to your wireless device, but it provides you with the opportunity to opt out of such messages in the future. Enterprise PCS does not send mobile-message (i.e., text messages as opposed to SMS messages) advertisements to your wireless device without your prior consent. If you have consented to receive such commercial mobile messages from us, you may change your preference at any time by sending an email to customercare@EnterprisePCS.com or by calling our Customer Care representatives at the number shown on your bill. Remember, you will still receive customer-service or account-related messages from Enterprise PCS. Finally, if you opted in to receive commercial mobile messages from third parties, you must opt out with them directly. Enterprise PCS is not responsible for commercial mobile messages sent by unauthorized third parties, including those who purport to be selling Enterprise PCS products or services. Enterprise PCS maintains an anti-spam filter in an effort to block as many unwanted messages as possible but inevitably, some unwanted messages will get through the filter. You may report such messages to Customer Care.
Email. Enterprise PCS maintains a "do-not-email" list for those recipients of commercial email messages from Enterprise PCS who have opted out of such communications. You may opt out of email by sending an email to customercare@EnterprisePCS.com, calling our Customer Care representatives at the number shown on your bill, or, by following the opt-out instructions in the email for up to 30 days after receipt. Enterprise PCS will honor your request within thirty (30) business days. Remember, you may still receive customer-service or account-related messages from Enterprise PCS. Enterprise PCS is not responsible for commercial email messages sent by unauthorized third parties, including those who purport to be selling Enterprise PCS products or services but do not have our permission.
Enterprise PCS or its agents may store e-mail messages for a brief period of time. Enterprise PCS or its partners may, without legal process, access and disclose the messages to protect both an individual during emergencies, or Enterprise PCS from unlawful or fraudulent use of its services. Additionally, you may store some information, such as pictures, for longer periods of time. Enterprise PCS may access and disclose such media without legal process to protect an individual during emergencies, or Enterprise PCS from unlawful or fraudulent use of its services.
Direct Mail. Personal accountholders may request not to receive promotional direct mail from us by sending an email to customercare@EnterprisePCS.com or calling our Customer Care representatives at the number shown on your bill. Of course, you will still receive account-related information (such as your invoice) by mail.
Facsimile. Enterprise PCS does not send commercial information by fax, unless you request such information to be sent by fax. You may email our Office of Privacy at customercare@EnterprisePCS.com or call our Customer Care representatives at the number shown on your bill if you believe you have received an unwanted fax from Enterprise PCS. Our business and government customers should contact their account representative. Enterprise PCS is not responsible for commercial fax messages sent by unauthorized third parties, including those who purport to be selling Enterprise PCS products or services but who do not have our permission.
Customer Proprietary Network Information ("CPNI"). There are special rules related to the access, use and disclosure of customer proprietary network information or "CPNI." This Policy incorporates those rules throughout. You have a right, and Enterprise PCS has a duty, under the law, to ensure the confidentiality of CPNI. In other circumstances, we may also disclose your CPNI as permitted by law.
Your name, address and phone number are not CPNI, but otherwise are covered by this Policy.
We may use your CPNI to market additional communications and data products and services similar to the types you currently purchase from us. For example, a wireless customer can be marketed wireless Internet access, new messaging products, location-based services, interactive services, or photo or message storage, handsets or related equipment. With your opt-out permission we may also market additional products and services we and our partners sell. For example, we may sell long distance to you as a wireless customer. We may also use CPNI to contact former customers when permitted by law. And, to provide your service, we may use and disclose CPNI to our agents, affiliates, joint venture partners and independent contractors, but we restrict their use and limit disclosure of CPNI for purposes or providing service to you or to market products and services as previously described. We will also prohibit the third party from further disclosing the CPNI except as required by law and require the third party to implement safeguards to protect the confidentiality of the CPNI. If you are a new customer of Enterprise PCS, you will receive a notice of your CPNI rights and further information on this topic from Enterprise PCS. When you have not already given Enterprise PCS your permission to use CPNI for marketing purposes, Enterprise PCS will give you 33 days after soliciting your consent before using your CPNI and Enterprise PCS will follow your directions if you choose not to provide your consent.
Enterprise PCS and its employees shall take reasonable measures to discover and protect against attempts to gain unauthorized access to CPNI. All employees must properly authenticate a customer prior to disclosing CPNI during customer-initiated calls, online account access, or in-store visits.
�Call detail information� means any information pertaining to specific calls, including numbers called to/from, time, duration, or location of calls. Amount of minutes used or remaining minutes of use are not call detail records. When a customer calls a Enterprise PCS representative or authorized dealer, the Enterprise PCS representatives may only disclose call detail information under the following circumstances: (1) If the customer gives his or her password, established online or through the customer�s account. The password may not use readily available biographical information such as addresses, SSN, or driver�s license numbers. The representative may refer the customer to the Enterprise PCS website to establish a password, or call the customer back on the Enterprise PCS Wireless number associated with the requested records to establish a password for future call detail requests; (2) If the customer does not have a password, call detail information may be disclosed if the representative sends the information to the address on the customer account or by calling the customer back on the Enterprise PCS Wireless number associated with the requested records. Representatives may not call a different number to disclose information, and may not send the call detail records to any other address than that on the account; and (3) If the customer is able to provide call detail information to the representative, then the representative may discuss the information provided by the customer.
Online account access via our website shall require online authentication prior to disclosing CPNI. Such authentication shall not use account information or readily available biographical information such as addresses, SSN, mother�s maiden name or driver�s license numbers.
In the event a Customer forgets or loses his or her password, a back-up method may be used to authenticate a customer. The back-up method may not prompt the customer for account number or readily available biographical information.
Retail sales associates and Dealers may disclose CPNI to a customer, provided the customer presents a valid photo ID matching the customer�s account information.
Enterprise PCS may utilize other authentication procedures not described here for services provided to businesses, provided that the account has a dedicated account representative, and that the account has a contract specifically addressing Enterprise PCS protection of CPNI.
Enterprise PCS shall notify the customer via voicemail, text message, or US mail, anytime a customer�s password, response to back-up question, online account information, or address of record is created or changed. This notification is not required when the new customer initiates service, but is required when a current customer obtains a password via the Enterprise PCS website.
Enterprise PCS has designated a CPNI Compliance Officer who is responsible for: (1) communicating with the Company�s attorneys and/or consultants regarding CPNI responsibilities, requirements and restrictions; (2) supervising the training of Company employees and agents who use or have access to CPNI; (3) supervising the use, disclosure, distribution or access to the Company�s CPNI by independent contractors and joint venture partners; (4) maintaining records regarding the use of CPNI in marketing campaigns; and (5) receiving, reviewing and resolving questions or issues regarding use, disclosure, distribution or provision of access to CPNI.
DISCLOSURE OF PERSONAL INFORMATION
This section of the Policy explains when personal information may be disclosed.
Vendors. We may share personal information with a third party to complete a transaction you have requested or to perform a service on our behalf. When the third party acts solely on our behalf, Enterprise PCS does not allow it to use your information for other purposes. For example, our vendors process and print your billing statement on our behalf. They can only use the personal information we give them to produce the billing statement.
Your Disclosures to Third Parties Through Our Services. You may also want to take advantage of services and products offered by other companies through our wireless services. In those cases, you will be providing information to those companies directly, and information about you received by those third parties will be governed by their privacy policies, not this Policy. For example, if you are roaming on the network of another carrier, information about your usage and the numbers you dial will be available to the carrier providing the service. Also, as another example, if you purchase something using our mobile Internet service, you will be disclosing personal information directly to the company facilitating the transaction, a merchant bank and the merchant. And, if you bought your wireless device from a third party retailer or dealer, both they and Enterprise PCS will have personal information as a result of the transaction. Whenever third parties have a role in any such transaction, you should review their privacy policies as well.
Contests and Promotions. From time to time you may be able to participate in contests, giveaways or other similar promotions we sponsor. Participation may require sharing your personal information with a sponsor of the contest, giveaway, or promotion, and you should check the rules to determine how your information will be used and shared with others. Some states also require that contest winners be filed with a state agency.
Business Transfers. Information about our users, including personal information, may be disclosed as part of any merger, acquisition, sale of company assets or transition of service to another provider, as well as in the unlikely event of an insolvency, bankruptcy or receivership in which personal information would be transferred as one of the business assets of the company.
Protection of Enterprise PCS and Others. We disclose personal information when we believe release is appropriate to comply with the law (e.g., legal process, E911 information); to enforce or apply our customer agreements; to initiate, render, bill, and collect for services; protect our rights or property, or those of users of our services; to protect other service providers from fraudulent, abusive, or unlawful use of, or subscription to, such services; facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government requirement, or eligibility for government benefits; or if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.
PRESENCE, LOCATION AND TRACKING INFORMATION
To make wireless communications possible, our network knows the general location of your phone or wireless device whenever it is turned on. Your wireless device sends out a periodic signal to the nearest radio tower/cell site so that our network will know where to route an incoming communication and how to properly bill for the service. This is necessary to make wireless communications possible. Location information derived from providing our voice service, in addition to being covered by this Policy, is CPNI and is protected as described above.
If you dial 9-1-1 for emergency services, we provide your call location to a public safety answering point, emergency medical service provider or emergency dispatch provider, public safety, fire service, or law enforcement official, or hospital emergency or trauma care facility. The law also permits us to disclose the call location of a device on our network without a user's consent (1) to a user's legal guardian or members of a user's immediate family in an emergency situation that involves the risk of death or serious physical harm, (2) to database management services or information providers solely to assist in delivering emergency services, (3) if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires or justifies disclosure of a device's location on the network without delay, and (4) in "aggregate" form. Aggregate data is collective data that relates to a group or category of services or customers, from which individual customer identities and characteristics have been removed.
We offer wireless location-based applications that use your wireless network location to provide the service you request. For example, you may choose to subscribe to a service that provides driving directions on your wireless device. Please review the terms and conditions for each service for additional information about how the location information will be used or disclosed. It is important to note, if you let others use location-based services to which you've subscribed as the account holder (or if you let others use your handset if such handset has location tracking capabilities), it is your responsibility to inform that user that his or her location may be tracked.
Your wireless Internet service may also be personalized using your zip code or other location identifiers. We use this information to serve you relevant content, and we treat the information like any other personal information under this Policy.
COOKIES AND WEB BEACONS ON THE WEBSITE
Cookies are small files placed on your computer's hard drive by a Website when you visit. These files identify your computer and record your preferences and other data about your visit so that when you return to the site, the site knows who you are and can personalize your visit. For example, cookies enable a Website shopping cart to function so that you only have to check out once. Consequently, cookies are often tied to the use of personally identifiable information while using our site and some functionality may be lost if you choose not to accept the use of cookies.
In general, we use cookies to collect information so that we can determine how to improve our site by seeing which areas, features and products are most popular; to personalize the site and make recommendations based on products you have liked in the past as well as to improve the site experience; and to complete transactions you have requested. Advertisers that serve ads on our site may also use their own cookies. Such outside cookies are governed by the privacy policies of the entities placing the ads, and are not subject to this Policy.
We also use a session-based cookie that maintains a user's session for continuity of navigation while viewing the site. After closing the browser the session cookie simply terminates.
With wireless Internet service, cookies are also used by our suppliers and third party vendors to facilitate the various services and information offered. Depending on the phone or device being used, cookies may be stored locally on the phone or device, or on servers operated by Enterprise PCS. This Internet cookie-like functionality is in place for the same reasons and designed for the same purposes as cookies placed on your computer when interacting with Internet Websites. Each site you visit while using the wireless Internet service is controlled by a separate company and their individual privacy policies will govern information they receive automatically from the cookie or information you voluntarily provide.
A Web beacon, also known as a Web bug, is a small, graphic image on a Web page, Web-based document or in an e-mail message that is designed to allow the site owner or a third party to monitor the address and other information of the site viewing the item. Web beacons are often invisible to the user because they are typically very small (only 1-by-1 pixel) and the same color as the background of the Web page, document or e-mail message. Web beacons are represented as HTML IMG tags in the Web page; users can click on "view profiles" of the Web page to see whether the page is using a Web beacon. Web beacons collect the IP address of the computer to which the Web beacon is sent, the URL of the page from which the Web beacon comes, and the time it was viewed. Web beacons can also be linked to personal information.
Enterprise PCS may place Web beacons on its site in conjunction with cookies to monitor how visitors are navigating and/or interacting with the site. Enterprise PCS does not link Web beacons to a visitor's personal information and generally does not permit third parties, other than those working on our behalf, to place them on our site.
Enterprise PCS PLACEMENT OF BANNER ADS ON OTHER WEBSITES
Enterprise PCS may use third-party advertising companies to place advertisements about our products and services on other Websites. The advertising companies may use cookies and other technology such as Web beacons or tagging to measure the effectiveness of our ads. To measure advertising effectiveness and offer selective ad content, the advertising companies may use anonymous information about your visits to our and other Websites. The use of such cookies is subject to the advertising company's privacy policy, not the policy of Enterprise PCS.
NETWORK AND INFORMATION SECURITY
We maintain a variety of physical, electronic, and procedural safeguards to guard your personal information. For example, we take a variety of steps to protect against unauthorized access to our systems that store personal information such as policies limiting access to those systems to authorized personnel.
When you are ordering new services or products through the Enterprise PCS Website, we employ standard security measures to assure the security of your ordering information. You should be aware that Enterprise PCS has no control over the security of other sites on the Internet you might visit, interact with, or from which you buy products or services.
You should keep your user name, password or other access information safe and confidential to protect against unauthorized access to your account information and services. And you must adopt passwords that others may not guess easily.
RETENTION OF INFORMATION
Enterprise PCS retains all of the information it collects under this Policy for as long as there is a business need for it. In addition, we have a record retention policy that generally implements the broad range of regulatory requirements imposed on service providers for recordkeeping.
CHECKING ACCOUNT INFORMATION FOR ACCURACY AND ACCESSING YOUR REGISTRATION PROFILE
To change your contact, phone, account or e-mail preference information please contact: customercare@EnterprisePCS.com.
UPDATING THIS POLICY
enterprisepcs will update this Policy if our practices change or if the law requires changes to it. If at any point we decide to use personally identifiable information in a manner that is materially different from what was stated at the time it was collected, we will notify you via posting on this page for 30 days before the material change is made and give you an opportunity to opt out of the proposed use at any time. CONTACTING US If you have any questions about, or complaints that concern, this Policy, please visit Customer Care Online or email us at customercare@enterprisepcs.com or call Customer Care at the number shown on your bill. If you prefer, you also may write us at Privacy Department, 11400 SE 8th St., Bellevue, WA 98004. Our representatives will respond to your inquiries or help resolve any dispute concerning this Online Privacy Policy.