LDC Group is committed to respecting and protecting the privacy of our customers. As discussed below, we have strict policies governing access by employees and others to customer communications and information. We access customer accounts, records or reports for authorized business purposes only. We educate our employees about their obligation to safeguard customer information and communications, and we hold them accountable for their actions. In short, privacy is a priority for LDC Group in all aspects of our business.
GENERAL PRIVACY PRINCIPLES
The following principles express LDC Group’s commitment to assuring strong and meaningful customer privacy protection, and are intended to guide LDC Group’s efforts to balance customer privacy with customer interest in receiving quality services. These principles apply to our use of “individual” customer information – that is, information about specific customers. These policies are fully consistent with applicable laws and regulations governing privacy, including the regulations of the Federal Communications Commission (“FCC”). Individual customer information is distinct from “aggregated” customer information, which does not reveal a customer’s identity. Further, the examples provided below are intended to be illustrative, not all-inclusive.
LDC Group obtains and uses individual customer information for business purposes only.
LDC Group obtains and uses customer information that helps us to provide our customers with quality telecommunications services. In addition to supporting the direct provision of service, this information may be used to protect customers, employees and property against fraud, theft or abuse; to conduct industry or consumer surveys; and to maintain good customer relations. Access to databases containing customer information is limited to employees who need that information to perform their jobs. These employees are required to follow strict rules when handling customer information, and are subject to disciplinary action if they fail to do so.
In order to better serve our customers, we may ask them questions to elicit additional information about their special needs and interests. For example, we may ask whether customers work at home, whether any members of the household have special needs, or whether teenagers reside in the household in order to determine whether customers may be interested in or might benefit from additional lines or services. In all cases, the information we gather is used to facilitate the provision of quality customer service. We do not share this information with third parties to market non-LDC Group services to our customers.
LDC Group uses the information we collect online principally to provide you with the service you have ordered and to inform you of other offerings that you may find interesting. Postal and e-mail address information enable us to communication with you about services offered and ordered, as well as the proper provisioning and billing of those services.
LDC Group may use third-party vendors to carry out certain functions in marketing and delivering services to you (such as processing data files and sending you new order fulfillment information), and so shares online data with those vendors to the extent necessary for them to perform their work. Such partners and vendors must use that personally identifiable information only for the purpose(s) for which it was shared and protect it from any further use. LDC Group also shares such information with other industry and credit-related organizations to improve operations and to protect against fraud, security and credit risks.
We also provide personally identifiable online information in response to subpoenas and other legal demands, and where we believe that disclosing this information is necessary to identify, contact or bring legal action against individuals who may be endangering public safety or interfering with LDC Group property or services.
LDC Group collects information online and other by asking you for it. A customer’s name, address (postal and e-mail) and telephone number are the most important pieces of information, but we might request other information, based on, for example, the service(s) being ordered or promoted.
LDC Group may also use “cookies” and similar technology to obtain information about your visits to our sites or your responses to email from us – both individually and in aggregated data that does not identify you. These reporting tools tell us the parts of our Web site or emails in which you showed an interest or took some action, and help us improve the quality and usefulness of our sites.
Another way in which we collect information online is through our affinity program partners who may provide us with information they have already obtained from you online or other. For example, when you are on a partner’s site and click on a LDC Group banner that takes you to the LDC Group site, information that the partner has received from you already may be passed to LDC Group.
We use encryption, firewalls and other technology and security procedures to help protect the accuracy and security of your personal information and prevent unauthorized access or improper use. For example, you will note that while using some features of the LDC Group website and online services, you will need to submit a password or some other type of authenticating information.
Customer Proprietary Network Information (“CPNI”) – We also want you to be aware that certain information related to your telecommunications services account with us such as to whom, where and when you make calls is CPNI. CPNI is protected by specific federal laws and regulations and as such we are fully committed to comply with such laws and regulations, both through our Web site and in all other respects. Without your consent, we will only share or disclose your CPNI (i) to market to you services or products among the categories of services or products you currently subscribe, (ii) to initiate, render, bill and collect our telecommunications services, (ii) to protect you or other carriers from illegal or fraudulent use of, or subscription to, our services or to protect our rights or property, (iii) to provide your call location information in certain specified emergency situations, and (iv) for other legally permissible purposes.
Typically, companies like LDC Group collect the data described above through the ordinary course of the customer-carrier relationship. When necessary, LDC Group uses such information to fulfill orders, provide service, bill, and communicate with customers. We may also use such data to develop new products or services tailored to fit customers’ specific needs.
LDC Group protects all CPNI in the control of LDC Group, and treats such information in a manner consistent and in compliance with Federal Communications Commission (FCC) requirements.
Except as set forth in this policy or unless we specifically disclose it to you at the time of collection or subsequently obtain your approval, we will not make any personally identifiable information that is gathered on our site available to unaffiliated organizations for commercial purposes unrelated to the business of LDC Group.
Certain federal, state and local laws or government regulations may require us to disclose personally identifiable information about you. In these circumstances, we will use reasonable efforts to disclose only the information required by law, subpoena or court order to be disclosed.
Feedback – At times we may ask you for contact information or conduct on-line surveys in order to better understand your needs in order to provide you with a customized experience. If we wish to use this information other than as set forth in this policy, we will let you know at the time of collection. We will take commercially reasonable steps to safeguard this information from unauthorized access. However, any aggregate data that you send to us such as your questions, suggestions, ideas or other creative material (“Feedback”) belongs to us and will not be treated as confidential. We may use, reproduce, adapt, distribute, display, disclose or create derivative works from Feedback without acknowledgement or compensation to you.