Effective Date: 12/17/2019
Information We Collect
We may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, in physical locations, through the mail, and/or over the telephone. More specifically, CapTel collects the following categories of Personal Information from its Consumers, which will depend on the particular Business Purpose for which we collect it. For more information on the Business Purpose, please refer to the How We Use Personal Information section of this policy.
||Examples of Personal Information Collected
||A real name, postal address, online identifier, Internet Protocol address, email address, account name, date of birth, last 4 digits of Social Security number.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
||A name, signature, last 4 digits of Social Security number, address, telephone number, credit card number, debit card number, bank account number.
|C. Protected classification characteristics under California or federal law.
||Age, hearing loss information.
|D. Commercial information.
||Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|E. Biometric information.
|F. Internet or other similar network activity.
||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
|G. Geolocation data.
|H. Sensory data.
|I. Professional or employment-related information.
|K. Inferences drawn from other personal information.
Personal information does not include deidentified or aggregated consumer information.
Company obtains the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications, among other things.
- Third parties. We may collect or receive information about you from other businesses we work with to deliver our services to you. For example, when you register your phone with us or purchase your phone, we may collect or receive information about or from your telecommunications relay service provider (“TRS Provider”).
How We Use Personal Information
We may use or disclose the Personal Information we collect from you or about you to do one or more of the following:
- To fulfill or meet the purpose for which you provided the information. For example, if you provide your personal information to purchase a product or service, we will use that information to deliver that service, including processing your payment. If you share your name and contact information to ask us a question or inquire about our products or services, we will use that personal information to respond to your inquiry.
- To register your phone to process calls through a TRS Provider and to facilitate service from a TRS Provider with whom you intentionally interact.
- To provide other services relating to your phone, including responding to 911 calls or other emergencies.
- To contact you and to inform you about products, services, special offers, and/or events that may interest you.
- To inform you about products and services you have purchased from us.
- To provide, support, personalize, and develop our website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- If you provide your information in the context of an employment application or your employment, we will use your information to serve those purposes.
- To personalize our services to you, including your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, mobile applications, and third-party sites. To help maintain the safety, security, and integrity of our products, services, and/or website, databases and other technology assets, and business.
- For research, analysis, and business development, including to develop and improve our website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA or subsequently agreed to by you.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Consumers is among the assets transferred.
How We Share Personal Information
Company may disclose your Personal Information to a third party for a business purpose, including to our service providers.
We share your personal information with the following categories of third parties:
- Service providers.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Sales of Personal Information
In the preceding twelve (12) months, Company has not sold personal information.
Your Consumer Rights and Choices
The CCPA provides Consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Company disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we disclosed your Personal Information for a business purpose, a list identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Company delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
In accordance with the CCPA, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. We do not disclose your Personal Information to third parties for their direct marketing purposes.
Changes to Our CCPA Privacy Notice
Company reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the App and Website and update the notice’s Effective Date above. Your continued use of our App or Website or interaction with us through other methods following the posting of changes and/or our directing you to the updated CCPA Privacy Notice constitutes your acceptance of such changes.