COLLECTION, USE, DISCLOSURE, AND SECURITY OF PERSONAL INFORMATION
This policy applies to personally identifiable information (“personal information”), which is information that we directly associate with a specific person or entity (for example, name; addresses; telephone numbers; social security number; call records; wireless device location). Personal information does not include “anonymous” or "aggregate" information – neither of which are associated with a specific person or entity.
Collection of Personal Information
We collect personal information about you when you use our services or otherwise interact with us. Such information includes:
Use of Personal Information
We use personal information for a variety of business purposes, including for example, to complete transactions and bill for products and services; verify your identity; respond to your requests for service or assistance; anticipate and resolve actual and potential problems with our products and services; create and improve products and services; suggest additional or different products or services; collect for our services; make internal business decisions about current and future offers; provide personalized service and user experiences; protect our rights and property; and contact you other about other services offered by ZERO11 Wireless. We may disclose personal information to personnel employed by our parent or affiliated companies in order to further any business purposes, including those described in this policy.
Third-parties may also use personal information to contact you about their products, services, and offers that we believe you will find of interest.
We may contact you by telephone, postal mail, e-mail or other methods. You may opt-out of receiving marketing communications from us at any time as outlined below in the section titled Customer Control.
Disclosure of Personal Information
We do not sell, rent, or otherwise provide your personal information without your consent, to unaffiliated third-parties (parties outside the ZERO11 wireless® corporate family) to market their services or products to you. We may, however, disclose your personal information to unaffiliated third-parties as follows:
Security and Retention of Personal Information
We use a variety of physical, electronic, and procedural safeguards to protect personal information from unauthorized access, use, or disclosure while it is under our control. Although we cannot guarantee that loss, misuse, or alteration of your personal information will not occur, we undertake commercially reasonable measures to prevent such occurrences.
Our practices and procedures are designed to limit personal information access to those ZERO11 wireless® employees and agents with a legitimate need to access such information. The employees of ZERO11 wireless® and our parent and affiliated companies are bound by confidentiality obligations and a Code of Conduct, which obligate them to protect the confidentiality of our customers’ personal information. Violations subject employees to disciplinary action, up to and including termination. We contractually require third-parties acting on our behalf to protect our customers’ personal information in a manner consistent with this policy.
We retain personal information for as long as we have a business need or as applicable laws, regulations, or government orders require. As required by law, we will make reasonable attempts to notify you if we determine that a security breach involving your personal information has occurred.Access and Choice
Not all marketing communications you receive on your device are sent or authorized by ZERO11 Wireless. When you provide your cell phone number or other contact information to others, you may receive unwanted calls, text messages, or e-mails on your device.
OTHER PRIVACY INFORMATION
When you use ZERO11 wireless® communications services, your name and telephone number may be transmitted and displayed on the receiving party’s communications device and/or phone bill.
We do not solicit children to purchase our services or products. If, however, you authorize a child to use our services or products by providing them a device associated with your ZERO11 wireless® account, any personal information associated with such use will be treated as your information in accordance with this policy. Our Web sites are not designed to attract children under the age of 13 and we do not intentionally or knowingly collect personal information on our sites from anyone under the age of 13. We encourage parents to be involved in the online activities (including wireless Internet browsing) of their children to ensure that no information is collected from a child without parental permission.
Cookies, Web Beacons, and Similar Technologies
Customer Proprietary Network Information (CPNI)
Customer Proprietary Network Information, or "CPNI", is a form of personal information that is generated in connection with the telecommunications services we provide to you. CPNI includes, for example, call details, call location information, and certain information about your rate plans and features. CPNI does not include your name, address, and phone number. Under federal law, you have a right, and we have a duty, to protect the confidentiality of CPNI and we have adopted policies and procedures designed to ensure compliance with those rules. We won’t intentionally disclose your CPNI to third-parties without your permission, except as allowed under FCC rules, applicable law, or explained in this policy. However, you may designate other “authorized users” (for example, a spouse) to access and manage your account information, including CPNI.
We provide password protected online access to your account information through www.ZERO11 Wireless.com. For multi-line accounts, the primary account holder is authorized to access online account information for all the devices on the account.
Customer Service Monitoring
We may monitor and record phone calls, e-mails, or other communications between you and our Customer Service representatives or other employees for training and quality assurance purposes and to review specific transaction requests.
We do not publish directories of our customers’ wireless numbers. Nor will we provide or make such numbers available to third-parties for listing in their public directories, without the customer’s prior consent.
Forums and Chat Rooms
If you use or link to a public forum, bulletin board, chat room, or social network on or from a ZERO11 wireless® web site, be aware that any personal information you submit can be read, collected, or used by other users of these forums, including to send you unsolicited messages. We are not responsible for access to or use of personal information you choose to submit or share with others.
Our network may detect your device's approximate location whenever it is turned on (subject to coverage limitations). This location technology makes the routing of wireless communications possible and is also the basis for providing enhanced emergency 9-1-1 service (if applicable to your Zero11 wireless® service), which permits us to provide your general location to a public safety answering point, emergency medical service provider, or emergency dispatch provider. We may also use this technology to disclose, without a user’s consent, the approximate location of a wireless device to a governmental entity or law enforcement authority when we are served with lawful process or reasonably believe there is an emergency involving risk of death or serious physical harm.
Network Information Storage
Some devices may automatically upload to ZERO11 wireless® network servers information you have stored on the device and/or SIM card in order to facilitate specific functions. For instance, some devices back-up your address book. If possible, you may choose to disable such uploads but this may affect functionality of the device or your services. Refer to instructions for your device and service or for details or contact Customer Service for more information. We may also provide you the ability to upload other information from your device to ZERO11 wireless® network servers. For instance, you may have the option to upload pictures, recordings, calendars, tasks, or notes. Uploaded information will not be used by ZERO11 wireless® for purposes other than as disclosed in connection with those services, this policy, or applicable Terms and Conditions.
Other Governing Terms
This policy does not modify or alter any applicable agreement you have with ZERO11 Wireless. If you use or subscribe to our products and services, our ZERO11 wireless® Terms and Conditions and certain other terms may apply to your use, purchase, or subscription. If this policy conflicts with any portion of those terms and agreements, those terms and agreements govern to the extent of the inconsistency.
Protecting Your Own Personal Information
Many devices store information both in the phone and on the SIM card. Therefore, before discarding, trading in, or giving away your device, be sure you remove and retain your SIM card and follow the manufacturer's instructions for deleting personal information or other data on the device. (This can be found in your owner's manual or on the manufacturer’s Web site.) If you provide a third-party access to your device, you should understand that personal information will remain on the device and may be accessible, deleted, altered, or transferred to another device or our network servers by the person using the device, and that we will treat that user as you for purposes of this policy.
We encourage you to use passwords to prevent unauthorized access to your device, your online account, and your voicemail. We recommend that you use unique, non-obvious passwords, that you periodically change your passwords, and that you not share your passwords with others. Notify us immediately if you believe your device has been lost or stolen or if you believe your personal information has been accessed without your consent.
Third-Party Applications for Your Devices
When you install third-party applications (for example, programs, widgets, etc.) on your device, you may give your consent for the third party to access certain information you have stored on your device (for example your contact list). You may also give your consent for the third party to access information stored on ZERO11 Wireless’s network to facilitate the application’s functions (for example, you may have given your consent to third-parties to access your location information). In either case, the manner in which such third-parties may use, share, or disclose such information is governed by their terms and conditions and their privacy policies – not this policy.
Wireless Communications Security
We cannot guarantee that your communications using our services or devices will be private or secure. Although it is illegal for unauthorized persons to intercept or access your communications or information, such interceptions or access can occur.
POLICY UPDATES AND CONTACT INFORMATION
Changes to This Policy
We may update this policy if we materially change our practices or if legal or regulatory changes require it. If we decide to use or disclose personal information in a way that is materially different from that which was stated in this policy at the time the personal information was collected, we will notify you by posting notice of the change on our Web site's home page for at least 30 days before we implement that change. You should refer to this policy often for the latest information and the effective date of any changes.
How to Contact Us
If you have any questions or comments about this policy or about ZERO11 Wireless' privacy practices, please contact us at www.zero11wireless.com or call us at 877-724-8325. You may also direct your privacy-related comments or questions to the address below:
c/o Americatel Corporation
Attn: Privacy Officer
7361 Calhoun Place, Suite 520
Rockville, MD 20855