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Spectrum Customer Privacy Notice for Cable Television, HSD Internet and Phone Service
Updated December 2016
Bright House Networks’ parent, Charter Communications Operating, LLC and the respective subsidiaries providing you the services (“Spectrum”, “we”, “us”, or “our”) is committed to respecting and protecting your privacy. This privacy notice applies to those Spectrum customers who subscribe to our cable television services, high-speed Internet services, and phone services (individually and collectively, the “Service”). This privacy notice gives you a general understanding of how Spectrum protects your privacy in connection with our provision of the Service, as well as your rights under the Cable Communications Policy Act of 1984, as amended and the federal Telecommunications Act of 1996, as amended.
We may modify this privacy notice at any time. We will notify you of any material changes through written, electronic or other means as permitted by law. If you find the changes unacceptable and if the change(s) materially and adversely affect your service, you have the right to cancel service. If you continue to use the service following notice of the changes, we will consider that to be your acceptance of and consent to the changes.
This notice is published at www.brighthouse.com where the most current version is maintained. You can call us for a printed copy at any time. We will mail a copy of this notice to you annually, whether or not there have been modifications. We encourage you to read this notice carefully and call us with any questions.
This notice only covers information about you that is collected by Spectrum in connection with the provision of our Service to you as a subscriber of our service (we refer to such information as “customer information”). This notice does not cover information that may be collected through any other products, services, or websites, even if accessed through our services and even if co-branded with our services. It also does not cover any Internet service provider other than our affiliate Road Runner. You should read the privacy policies for these other products, services, websites and providers to learn how they handle your personal information.
When we use the terms “Spectrum,” “we,” “us,” or “our” in this notice, we mean Spectrum and the family of companies we own or control. The term “you” or “customer” refers to you as a subscriber to one or more of our Services.
A. What types of customer information does Spectrum collect?
Spectrum collects customer information from you when you subscribe to and use our Service. Some of this information is collected automatically through your use of the Service, and some is collected when you voluntarily provide it to us, as may be required by law, and from third parties, as described in this notice. Some of the customer information we collect identifies you (we refer to that type of information as “personally identifiable information” or “PII”), but much of it does not. Personally identifiable information is any information that identifies you or can be used to identify, contact or locate you, including information that is used in a way that is personally identifiable, such as: your name, address, phone number, fax number, email address, birth date, names of household members, driver’s license or state ID number, social security number, bank account information, credit card information and other financial information. Personally identifiable information does not include aggregate data that does not identify a particular person or persons, or demographic information not connected to an identified individual or household, or non-personal information such as MAC addresses associated with set top boxes, modems, and routers, or other equipment identifiers that is not linked to PII.
When we first set up our services for you, and during any later changes or updates, we may collect technical information about your televisions, set-top boxes, computer hardware and software, cable modems, telephones, and/or other cable or other service-related devices, customization settings and preferences, and additional information about the service options you have chosen. We may also maintain research records containing information you give us through voluntary subscriber interviews or surveys.
In addition, as part of our normal course of business, we generate and maintain billing and account information such as billing, payment, and deposit history; the services to which you have subscribed; customer correspondence and communications records; and maintenance, repairs, and complaint information.
Sometimes, we also obtain additional information from outside sources to supplement the information we collect from you. We might add information about you or your community available from third parties such as research consultants and marketing firms (such as the information that merchants use in delivering catalogues by mail, or census information about neighborhoods).
If you rent your residence, we may have a record of whether landlord permission was required prior to installing our cable facilities as well as your landlord's name and address. We may also collect information from third parties to verify information you have provided and from credit reporting agencies to, for example, determine your creditworthiness, credit score, and credit usage.
We may also collect the following service-specific customer information depending on the specific Service to which you subscribe:
Phone Services. As part of delivering phone services, we keep information about the quantity, technical configuration, type, destination, location, and amount of your use of phone services, and calling patterns and information contained on your telephone bill concerning the phone services you receive. This information, when it is made available to us solely by virtue of our relationship with you, as a customer, is known as customer proprietary network information or “CPNI” and subject to special protections as described in Section D (“Special rules associated with customer proprietary network information”) below. Your name, address, and telephone number alone do not constitute CPNI when they have been published in a directory format, however.
If you subscribe to Spectrum Enhanced Voicemail service (which includes voicemail-to-email and voicemail-to-text service), we transmit, and may collect and store for a period of time, information generated by the service when you receive voicemail, including but not limited to audio recordings of such voicemail.
High-Speed Internet Service. If you subscribe to a Spectrum high-speed Internet service, such as Road Runner, we transmit, and may collect and store for a period of time, information generated by the service when you send and receive e-mail, video mail, and instant messages; transfer and share files; make files accessible; visit websites; or post blogs, comments, or other information. We do not store emails sent and received unless left in a Spectrum High Speed Internet account file. Spectrum may associate personal account information with data from third parties about you or similar persons to better predict your product and service preferences for use in programming, advertising transactions and to market our services to you. Unless addressed to us, we do not read email messages, instant messages, online chats, or the content of other online communications that reside on or pass through our networks. We may however, retain and provide such communications if we are legally required to do so. Incoming and outgoing email messages are generally scanned electronically to identify and filter out likely spam and for viruses and related problems that could harm your equipment, the network or other users.
Cable Television Services. If you are a cable television subscriber, we may also automatically collect information when you use our systems such as by ordering or viewing on-demand programming, or engaging in other interactive programming features. This information is primarily used to carry out the requests you make using your remote control, set-top box, or other equipment. It may also include other information such as the time you actually use our services, the use of other features of our services, and which menus and menu screens are used most often and the time spent using them. Information collected from these services is maintained on an anonymous basis, except in connection with billing for usage of video on demand or pay-per-view services or as necessary to fulfill any other request or order you make via the transactional and interactive services. Some of our advertisements may invite interactive or transactional follow-up from you. If you request products, services, features or information via such interactive advertisements, we collect and use the information generated by the request, including personally identifiable information when necessary, in order to carry out your request.
We may also collect channel tuning data to determine which programs are most popular, how many people watch a program to its conclusion and whether people are watching commercials, as well as other audience measurement-focused information. All personally identifiable information is removed from this data. Spectrum, or our contractors or agents, may from time to time share this anonymous information with our advertisers, content providers, or other third parties working on our behalf such as audience measurement or market research firms. These firms may combine this information with information about you or your community (such as the information that merchants use in delivering catalogues by mail, or census information about neighborhoods) to provide us with audience analysis data. Our audience measurement helps us and the program networks we carry decide on which programs and channels to carry and to improve our cable television services.
We also use this information to provide you with a more personalized experience by directing advertisers to the channels that produce more sales as they consider, design, and evaluate advertising campaigns.
In addition to this privacy notice, we may provide additional notices to you regarding specific advertising or other initiatives. These notices will describe the initiatives in greater detail and may, as appropriate, contain information you can use to choose to participate, or not participate, in these initiatives.
B. How does Spectrum use customer information?
We use customer information, including personally identifiable information, primarily to conduct business activities related to providing you with reliable, high quality Spectrum services, and to help us detect theft of service. More specifically, we may use personally identifiable information to:
- install, configure, operate, provide, support, upgrade and maintain the Spectrum services and service-related devices and software;
- bill and collect fees and charges for the Spectrum services;
- confirm you are receiving the level(s) of service requested and are properly billed;
- administer your account and identify you when changes are made to your account or services;
- provide you with customer and technical support;
- make you aware of products or services that may be of interest to you;
- understand the use of, and identify improvements to, our services;
- detect unauthorized reception, use, or abuse of our services;
- determine whether there are violations of any applicable policies and terms of service;
- manage the network supporting our services;
- maintain our accounting and tax records; and/or
- comply with applicable law.
We describe above in Section A how we use anonymous information relating to our transactional and interactive services, and Section D (“Special rules associated with CPNI”) below describes how we use CPNI.
C. When does Spectrum disclose customer information?
Spectrum will not disclose personally identifiable information to others unless (a) you provide appropriate consent in advance or (b) it is permitted or required under applicable law, as described below.
We may furnish your name and address to marketing organizations, programmers and other businesses. Section 631 of the federal Cable Communications Policy Act of 1984, as amended (the “Cable Act”) allows us to disclose this “mailing list” information unless you contact us and tell us otherwise.
We may also use or disclose customer information, including personally identifiable information, without your consent to protect our customers, employees, or property, in emergency situations, to enforce our rights under our terms of service and policies, if your account is referred to a collection agency or attorney, in court or elsewhere, and as otherwise permitted by law.
For all of the same purposes for which we use personally identifiable information as described in Section B above, we may sometimes disclose such information to our affiliates, agents, contractors, outside auditors, professional advisors, service providers and vendors, potential business merger, acquisition, or sale partners, and regulators. If a new company were to take ownership of our cable system, we reserve the right to disclose and transfer all customer information, including personally identifiable information, to the successor company. We describe above in Section A when we disclose to third parties anonymous customer information relating to our cable services.
D. Special rules associated with CPNI
We may also disclose customer information, including personally identifiable information, in connection with features and services associated with phone service, such as directory services, Caller ID, and 911/E911. We include your name, address, and telephone number in telephone directories we publish and in our directory assistance service, and provide it to third parties for directories and directory assistance. Once published, it may be packaged and provided by anyone. We take reasonable precautions to ensure that non-published and unlisted numbers are not included in our telephone directories or directory assistance services, but we cannot guarantee that errors will never occur. Your name and/or telephone number will be sent for display on Caller ID devices unless you elect to block it. (Please note that Caller ID blocking may not prevent that display when you dial certain business or emergency numbers, 911, or toll-free numbers.) We also provide your name, address, and telephone number to public safety authorities and their vendors for E911 and “reverse 911” use.
As part of delivering our services, federal law permits us to use and disclose CPNI to provide, bill, and collect for service, and to provide call location information for wireless phone service. Federal law and FCC rules also place restrictions on how we use CPNI for marketing purposes. However, they do permit us to use your CPNI to market other communications related products and services to you unless you object to such use as described in Section I below. If you agree, we may also use CPNI during any call you make to us to provide telemarketing, referral, or administrative services to you. We may also use CPNI to protect our rights and property, and protect users of our phone services and other carriers from fraudulent, abusive, or unlawful activities.
E. When is Spectrum required by law to disclose customer information?
We must disclose customer information, including PII, when required by the terms of valid legal process such as a subpoena, court order, or search warrant. If a court order requires us to disclose personally identifiable information to a third party non-governmental entity, we are required to notify you. If you subscribe to our cable television services and a government entity is seeking information regarding your selection of video programming, federal law requires that you be afforded notice of and the opportunity to appear and contest in a court proceeding relevant to the court order any claims made in support of the court order. At such a proceeding, the government entity is required to offer 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 prosecution of the case.
In some situations we may disclose personally identifiable information and CPNI about you to representatives of government or to comply with a court order without your consent and without advance or any notice to you, except that in these cases our disclosure is not to include records revealing your selection of video programming. In other situations (for example, if you owe or are owed welfare or child support), state welfare agencies may by administrative subpoena obtain your name, address, and other information as it appears in our records. We are required to notify the National Center for Missing and Exploited Children of information about child pornography that we become aware of in the course of providing our services. This information may be provided without a court order, and we do not have to give you notice and the opportunity to contest such disclosure.
If we notify you of specific legal requests or orders for personally identifiable information, and there is an opportunity for you to object to such disclosures, it is then up to you to object or take specific action to prevent these disclosures.
F. How does Spectrum protect customer information?
We take such actions as are necessary to prevent unauthorized access to customer information by a person other than you or us. We use security and encryption technologies to secure certain sensitive personally identifiable information we collect over the Service. We limit access to our customer database to those who are authorized, and secure its content with firewalls and other security methods. When we anonymize or aggregate information to remove your personal identity, we will use safeguards to reduce any risk of others identifying you from the anonymized or aggregated records. We cannot guarantee, however, that these practices will prevent every unauthorized attempt to access, use, or disclose personally identifiable information. We also expect you to protect your information and ensure that no unauthorized users can obtain any of our services or your information indirectly or directly from you.
G. How long does Spectrum maintain customer information?
We maintain customer information, including personally identifiable information, while you are a subscriber to Spectrum services. We also maintain customer information for a period of time after you are no longer a subscriber if the information is necessary for the purposes for which it was collected or to satisfy legal requirements. These purposes typically include business, legal, accounting or tax purposes. If these purposes no longer apply, we will destroy the information according to our internal policies and procedures.
H. Can I see the information that Spectrum collects about me?
You have a right to see the personally identifiable information about you that we collect and maintain in our regular business records. In most cases, the personally identifiable information contained in these records consists solely of billing and account information. If you would like to see your personally identifiable information, please contact us by mail or telephone, giving us a reasonable period of time to locate and, if necessary, prepare the information for review, and to arrange an appointment during regular business hours. You will only be permitted to examine records that contain personally identifiable information about your account and no other account. If your review reveals an error in our records, Spectrum will correct it. We reserve the right to charge you for the cost of retrieving and photocopying any documents that you request.
If you make a written request for a copy of your CPNI, we will disclose the relevant information we have to you at the address we have for your account, or to any person authorized by you, if we reasonably believe the request is valid. For telephone and online access to your CPNI such as outbound call detail records, we require that you first authenticate your identity using a password established using our online system. You can find out more about online access to your CPNI at www.brighthouse.com. We generally do not provide our subscribers with records of calls received, records that are only in our archives, other records that we do not furnish as part of a telephone bill, web-browsing history, IP address logs or any other information that we do not create or maintain in the ordinary course of business unless there is a court order or similar legal process. If there are errors in names, addresses, or telephone numbers in our vendors’ directory lists, or if you have been omitted from the directory, the correction cannot be made until the next available publication. Please understand that we may have no control over information appearing in directory lists or provided by directory assistance services which we do not own.
I. Can I prohibit or limit Spectrum’s use and disclosure of my customer information?
You have some choices in how we use or disclose customer information.
If you do not want to be included in mailing lists provided to third parties as explained in Section C, please contact us to be removed.
If you do not want to receive telemarketing calls from Spectrum, call us at one of our Business Offices to be placed on our Do Not Call list. To help reduce unwanted telemarketing calls, the FCC offers telephone subscribers the opportunity to register their residential telephone numbers in its national Do Not Call registry. You may register for the list without charge by calling the FTC at 1- 888-382-1222 or TYY 1-866-290-4236 from the telephone number you are registering or online at www.donotcall.gov. Registration will not eliminate all telephone calls to you from us, because we are still permitted to make calls related to your account.
If you do not want us to use your CPNI to market communications-related services to you, please contact us to prevent such use.
Occasionally, you may be asked during a telephone call with one of our representatives for your oral consent for us to use your CPNI for making such an offer for other services. If you agree, we will use your CPNI only for the duration of that telephone call.
If you deny or restrict your approval for us to use your CPNI, you will suffer no effect, now or in the future, on how we provide any services to which you subscribe. Any denial or restriction of your approval remains valid until your services are discontinued or you affirmatively revoke or limit such approval or denial.
J. Your California privacy rights
California law entitles our California customers to request additional information from a business which shares personally identifiable information with third parties for their direct marketing purposes. We do not share personally identifiable information with unaffiliated third parties, for their own direct marketing purposes. We may share personally identifiable information with some same-branded affiliates, however, for those affiliates’ direct marketing purposes. If you contact us, we will provide you with the names and addresses of our same-branded affiliates in California and a list of personally identifiable information that we may have shared with them.
K. How does Spectrum protect children’s privacy?
We do not knowingly collect personally identifiable information from anyone under the age of 13 over our Service. Our Services are not directed at, or intended for use by, children under the age of 13. Children should always get permission from a parent or guardian before sending personal information over the Internet. Other services or web pages accessed through our Service may have different policies on collection of information pertaining to children and you should consult their privacy policies and read their notices.
L. Cookies, tracking and targeted marketing
Spectrum may place “cookies” in your browser that contain customer information when you set up a personalized service or customize your settings and preferences on our websites or mobile applications. We do not store sensitive personally identifiable information such as your password, e-mail address or credit card number in cookies. Cookies enable us to control the display of ads, track usage patterns, help diagnose problems with our services, gather demographic information, analyze trends, conduct research, and otherwise administer the Service. Additionally, Spectrum uses a third party provider to place our internet ads. The provider uses “pixel tags,” an industry standard technology used by most major websites to collect anonymous information about your visits to our site and your interaction with our products and services. The provider may also use information about your visits to this and other sites to target advertisements for merchandise and services and to gauge the effectiveness of advertisements. No personally identifiable information, such as your name, address, phone number or email address, is collected or used in this process. If you would like more information about this practice and your option to not have this anonymous information used by our third party provider, please visit http://www.networkadvertising.org/choices.
You may opt out of the cookies delivered by Spectrum on its websites by changing the setting on your browser. Depending on your privacy settings, please be aware that this may disable all cookies delivered to your browser, not just the ones delivered by Spectrum. Because a “Do Not Track” protocol has not yet been finalized, Spectrum’s information collection and disclosure practices, and the choices that we provide to consumers, will continue to operate as described in this Privacy Notice, whether or not a Do Not Track signal is received.
Third-party ad serving companies and other unaffiliated advertisers may also display advertisements on our websites. As part of their service, they may place a separate cookie on your computer or utilize other means, such as, web beacons, clear GIFs, pixel tags or other similar technologies, to collect Non-Personally Identifiable Information, such as your IP address, browser type, the server your computer is logged onto, the area code and zip code associated with your server, and whether you responded to a particular advertisement. This use of these technologies by third parties is subject to their own privacy policies, not this Privacy Notice, and we have no responsibility or liability in connection therewith. To find out more about third party advertising and whether certain opt-outs are available, visit http://www.aboutads.info.
M. How do I contact Spectrum?
If you have any questions or suggestions regarding this privacy notice, or wish to contact us about your personal information, please contact us by mail at:
400 Atlantic Street, 10th floor
Stamford, CT 06901
or by email at: email@example.com
N. What can I do if I believe Spectrum has violated my privacy rights?
If you believe that you have been aggrieved by any act of ours in violation of law, we encourage you to contact us directly as described above in Section K in order to resolve your question or concern. You may also enforce the limitations imposed on us by the Cable Act with respect to your personally identifiable information through a civil lawsuit in federal district court seeking damages, attorneys fees, and litigation costs. Other rights and remedies may be available to you under federal or other applicable laws as well.