Southeast Nebraska Communications Privacy Policy

Transcription

1 Sutheast Nebraska Cmmunicatins Privacy Plicy Abut Our Privacy Plicy Whenever yu d smething like buy ne f ur prducts, stream a mvie r dwnlad an app, infrmatin is created. Because we knw yur privacy is imprtant, we have a Privacy Plicy t explain hw we cllect, use and prtect that infrmatin. There s a quick summary belw, and the entire plicy is written in an easy FAQ frmat. We want t simplify this, s yu can make infrmed chices abut yur privacy, and then spend the rest f yur time enjying ur prducts and services. Effective June 1, 2014 A Quick Summary f Our Privacy Plicy Our privacy plicy applies t yur use f ur prducts and services. We will always prvide yu with ntice f material changes t this Plicy. In rder t d things like cnstantly imprve ur services, prducts and relatinship with yu, we may cllect different types f infrmatin that help us learn mre abut hw yu use ur fferings. Here s sme f the infrmatin we cllect: Accunt Infrmatin includes yur name, address, telephne number, address, service-related details such as payment data, security cdes, service histry and ther infrmatin like that; Netwrk Perfrmance & Usage Infrmatin tells us hw yu use ur netwrk, ur prducts and ur services, and hw well ur equipment and netwrk is perfrming; Web Brwsing & Wireless Applicatin Infrmatin tells us abut the websites yu visit and the mbile applicatins yu use n ur netwrk; Lcatin Infrmatin tells us where yur wireless device is lcated, as well as yur ZIPcde and street address; Data Streaming/Vide Infrmatin tells us abut which prgrams yu watch and recrd, the games yu play, the applicatins yu use and similar infrmatin abut hw yu use ur services and applicatins. Here are the three basic ways we cllect it: We get infrmatin frm yu when yu d things like make a purchase frm us; We cllect it frm hw yu use ur prducts and services; Other surces, like credit agencies, marketing cmpanies, and ther service prviders, prvide it t us. Here are just sme f the ways we use it. T: Prvide services and imprve yur custmer experience; Send yu bills fr yur services;

2 Respnd t yur questins; Address netwrk integrity and security issues; D research and analysis t maintain, prtect, develp and imprve ur netwrk; Let yu knw abut service updates, ffers and prmtins; Imprve entertainment ptins; Deliver Relevant Advertising; Create External Marketing & Analytics Reprts; Assist in the preventin and investigatin f illegal activities and vilatins f ur Terms f Service r Acceptable Use Plicies. Sme examples f wh we share yur Persnal Infrmatin with: Acrss all SNC cmpanies t give yu the best custmer experience and t help yu get everything we have t ffer. With ther cmpanies that perfrm services n ur behalf nly as needed fr them t perfrm thse services. We require them t prtect yur infrmatin cnsistent with ur Plicy. With ther cmpanies and entities, t: Respnd t 911 requests and ther emergencies r exigencies; Cmply with curt rders and ther legal prcess; Assist with identity verificatin, and preventing fraud and identity theft; Enfrce ur agreements and prperty rights; and Obtain payment fr prducts and services including the transfer r sale f delinquent accunts t third parties fr cllectin Details n Persnal and Annymus & Aggregate Infrmatin What is Persnal Infrmatin? Infrmatin that identifies r reasnably can be used t identify yu. What is Annymus? This is infrmatin that desn t identify yu and can't reasnably be used t identify yu specifically. What is Aggregate? We take a whle bunch f peple s data and cmbine it int annymus grups r categries. Hw we use this infrmatin? We use and share this infrmatin in many ways including research, media analysis and retail marketing and Relevant Advertising. This data is als included in External Marketing &Analytics Reprts Our privacy cmmitments We dn't sell yur Persnal Infrmatin t anyne fr any purpse. Perid. We keep yur persnal infrmatin in ur business recrds while yu are a custmer, r until it is n lnger needed fr business, tax r legal purpses.

3 We will keep yur infrmatin safe using encryptin r ther apprpriate security cntrls. Our Online Privacy Plicy fr Children We want yu t knw that we dn't knwingly cllect persnally identifying infrmatin frm anyne under the age f 13 unless we first btain permissin frm the child's parent r legal guardian. Yur Chices & Cntrls Yu have chices abut which types f advertising yu get frm us; Yu can cntrl whether yur annymus infrmatin is used in ur External Marketing & Analytics Reprts; Yu can chse whether t receive marketing calls, s r text messages frm us; Yu have a chice abut hw we use yur Custmer Prprietary Netwrk Infrmatin; We understand that everyne thinks that privacy plicies are lng, cmplicated and difficult t understand. S we're ging t try t make this as simple as pssible. DEFINITIONS Let's start with what we mean when we say: Aggregate Infrmatin: Infrmatin that we cmbine int annymus grups f custmers r users. One way t think f it is in terms f a survey r pinin pll. Aggregate infrmatin wuld tell yu that 80 percent f the peple vted fr a candidate, but nt wh actually vted. These grups are large enugh t reasnably prevent individuals frm being identified. Annymus Infrmatin: Infrmatin that desn't directly identify and can't reasnably be used t identify an individual custmer r user. Custmer: Anyne wh purchases r uses ur prducts r services. When a custmer purchases retail prducts r services fr use by thers, like a family accunt, thse family members als are custmers. Mbile Applicatin: A sftware applicatin that runs n smartphnes, tablet cmputers r ther mbile devices and that allws users t access a variety f services and infrmatin. Persnal Infrmatin: Infrmatin that directly identifies r reasnably can be used t figure ut the identity f a custmer r user, such as yur name, address, phne number and address. Persnal Infrmatin des nt include published listing infrmatin. Relevant Advertising: Uses aggregate infrmatin abut grups f peple (like age, ethnicity, incme range, where thse grups live and wrk, and their interests) t develp advertising that is mre likely t be useful t that grup. It des nt use individual data abut what a specific persn might like. "Online behaviral advertising" is ne type f relevant advertising. It uses interest categries based n the websites visited by grups f peple t deliver advertising nline. User: Anyne wh visits ur websites r uses ur mbile applicatins. Website: And ther terms like "Internet site," "site" and "web page" all mean the same thing, namely any page r lcatin n the Internet, n matter what device (cell phne, tablet, laptp, PC, etc.) r prtcl (http, WAP, ftp r ther) is used t access the page r lcatin.

4 THE SCOPE OF THIS POLICY 1. What des this Plicy cver? This Privacy Plicy cvers ur practices regarding the infrmatin we cllect abut ur custmers and users (hw we cllect it and hw we use it). Use f ur prducts and services, as well as visits t ur websites, are subject t this Privacy Plicy. 2. What abut my family members and ther users f my SNC accunt? Des this Plicy apply t them? Yes. Yu're respnsible fr making sure all family members r ther users under yur accunt understand and agree t this Plicy. Get everyne tgether and talk abut it. Or, send it by t make sure they're n bard. Hang it n the fridge. Up t yu, just share it! 3. When is infrmatin nt cvered by this Plicy? Any time yu give infrmatin t cmpanies ther than SNC. Sme examples are: When yu use a nn-snc service; When yu dwnlad applicatins r make purchases frm ther cmpanies while using ur Internet r wireless services; When yu g t a nn-snc website frm ne f ur websites r applicatins (by clicking n a link r an advertisement, fr example); If yu use public frums - such as scial netwrking services, Internet bulletin bards, chat rms, r blgs - the infrmatin is publicly available, and we cannt prevent distributin and use f that infrmatin by ther parties; Infrmatin abut yur lcatin, usage and the numbers yu dial when yu're ut and abut and raming n the netwrk f anther cmpany; When yu purchase r use nn-snc prducts (such as wireless devices, internet brwsers and mbile applicatins) in cmbinatin with ur services. When we license ur brand t ther cmpanies fr their use in marketing and selling certain nn-snc prducts and services, infrmatin yu give thse cmpanies is nt cvered by this Plicy. 4. Can my infrmatin be cvered by this plicy and ther privacy plicies at the same time? Yes, that can happen. Fr example: Smetimes we will prvide a service with ther cmpanies. In that case yur infrmatin may be subject t this Plicy and that f the ther cmpanies. Fr example, if yu use SNC High Speed Internet services "pwered by" Yah! Inc., yur infrmatin may be cvered by bth this Plicy and the Yah Plicy. If yu purchase ne f ur prducts r services frm a retailer like Best Buy r Amazn.cm, fr example, any infrmatin yu prvide t them may be subject t bth their plicy and urs.

5 If yu cnnect t ur Wi-Fi service thrugh anther netwrk, such as ne prvided in a htel, airprt r ther venue, any infrmatin cllected frm yur use f that netwrk culd be subject t either the SNC plicy r the venue plicy, and smetimes bth. The same thing applies if yu cnnect t ur netwrk thrugh yur emplyer's crprate netwrk, r any netwrk perated by a nn-snc cmpany. We think it's a great idea t take a lk at the privacy plicies f any cmpanies yu d business with t learn hw they use yur infrmatin. 5. What abut business custmers? We have written prduct r service agreements with ur business custmers that cntain specific prvisins abut cnfidentiality, security r handling f infrmatin. When ne f these agreements differs frm r cnflicts with this Plicy, the terms f thse agreements will apply. In all ther instances, the terms f this Plicy apply. THE INFORMATION WE COLLECT, HOW WE COLLECT IT AND HOW WE USE IT 1. What infrmatin d we cllect? We may cllect different types f infrmatin based n yur use f ur prducts and services and n ur business relatinship with yu. Accunt Infrmatin: Cntact Infrmatin that allws us t cmmunicate with yu. We get this infrmatin when yu rder r register fr ur services. This wuld include infrmatin like yur name, address, telephne number and address. Billing Infrmatin related t yur financial relatinship with us, such as the services we prvide t yu, the telephne numbers yu call and text, yur payment histry, yur credit histry, yur credit card numbers, Scial Security number, security cdes and yur service histry. Technical & Usage Infrmatin related t the services we prvide t yu, including infrmatin abut hw yu use ur netwrk, services, prducts r websites. Sme examples include: Equipment Infrmatin that identifies yur equipment n ur netwrk, such as equipment type, device IDs, device status, serial numbers, settings, cnfiguratin and sftware. Netwrk Perfrmance & Usage Infrmatin abut the peratin f the equipment, services and applicatins yu use n ur netwrk. Examples f this might include wireless device lcatin, the number f text messages sent and received, vice minutes used, bandwidth used, and resurces yu use when uplading, dwnlading r streaming data t and frm the Internet. We als cllect infrmatin like transmissin rates and delays, data assciated with remte mnitring services and security characteristics.

6 Sme Netwrk Perfrmance & Usage Infrmatin and sme Billing Infrmatin is Custmer Prprietary Netwrk Infrmatin r "CPNI." Unique rules apply t CPNI. Web Brwsing & Mbile Applicatin Infrmatin such as IP addresses, URLs, data transmissin rates and delays. We als learn abut the pages yu visit, the time yu spend, the links r advertisements yu see and fllw, the search terms yu enter, hw ften yu pen an applicatin, hw lng yu spend using the app and ther similar infrmatin. Lcatin Infrmatin includes yur ZIP-cde and street address, as well as the whereabuts f yur wireless device. Lcatin infrmatin is generated when yur device cmmunicates with cell twers, Wi-Fi ruters r access pints and/r with ther technlgies, including the satellites that cmprise the Glbal Psitining System. Data streaming/vide Infrmatin is generated when yu use ur suite f services including TV, On Demand, High Speed Internet Service and prducts, including the prgrams and channels yu and thse in yur husehld watch and recrd, the times yu watch and hw lng yu watch. It als includes infrmatin like the games yu play and the applicatins yu use. 2. Hw D Yu Cllect Infrmatin? In three basic ways: Yu Give It T Us when yu make a purchase r set up an accunt with us; We Autmatically Cllect Infrmatin when yu use ur netwrk, prducts and services. Fr example, we use netwrk tls t cllect yur call recrds; we cllect wireless device lcatin frm ur netwrk and frm yur device; and we als use ckies, web server lgs and ther technlgies. We Obtain Infrmatin frm Outside Surces like credit reprts, marketing mailing lists, and cmmercially available gegraphic and demgraphic infrmatin. 3. Hw D Yu Use My Infrmatin? We use yur infrmatin t imprve yur experience and t make ur business strnger. Sme examples include: Prviding and managing yur services, respnding t yur questins and addressing prblems; Delivering custmized cntent, Relevant Advertising and persnalized ffers fr prducts and services that may be f interest t yu; Cmmunicating service updates, ffers and prmtins; Prtecting netwrk integrity and security, ensuring quality cntrl, ptimizing capacity and preventing misuse; Netwrk enhancement planning, engineering and technical supprt;

7 Cnducting research and analysis fr maintaining, prtecting and develping ur netwrk and ur services; Preventing illegal activities, suspected fraud, and ptential threats t ur netwrk and ur custmers netwrks; Investigating vilatins f ur Terms f Service, Acceptable Use Plicies, r ther service cnditins r restrictins; and Prtecting the safety f any persn. 4. D yu use the infrmatin I stre using ne f yur clud services? We nly use it t prvide yu with that service, unless we first get yur permissin t use it fr smething different. INFORMATION SHARING 1. D yu prvide infrmatin fr phne bks and Caller ID? Yes and N. Yes, we share the names, addresses and telephne numbers f ur wireline telephne custmers with businesses that publish directries and prvide directry assistance services. We are required by law t d that. We hnr yur request fr nn-published r nn-listed phne numbers. Once we prvide published listing infrmatin t thse businesses, they may use, srt, package, repackage and make it available again in different frmats t anyne. We als prvide calling name and number infrmatin fr Caller ID. N, we d nt give listing infrmatin fr wireless numbers t phne bk publishers r directry assistance services withut yur permissin. 2. D yu share my Persnal Infrmatin internally? Yes. Sharing this infrmatin internally helps us ffer yu the high quality, seamless and innvative range f prducts yu have cme t expect frm us. Sme f these include: The SNC suite f TV, Vice and High Speed Internet Access services ffered by us r ur sister cmpanies. If ne f ur subsidiaries des nt perate under the SNC brand, infrmatin sharing with that subsidiary is handled as thugh it is a nn-snc cmpany. 3. D yu share my Persnal Infrmatin with ther cmpanies fr them t market t me? We will nly share yur Persnal Infrmatin with ther cmpanies fr them t use fr the marketing f their wn prducts and services when we have yur cnsent. 4. Are there any ther times when yu might prvide my Persnal Infrmatin t ther cmpanies r entities?

8 Yes. We share yur Persnal Infrmatin with cmpanies that perfrm services fr us, like prcessing yur bill. Because we take ur respnsibility t safeguard yur Persnal Infrmatin seriusly, we d nt allw thse cmpanies t use it fr any purpse ther than t perfrm thse services, and we require them t prtect it in a way cnsistent with this Plicy. Cmpanies that perfrm these services may be lcated utside the United States r the jurisdictin where yu reside. If yur Persnal Infrmatin is shared with these cmpanies, it culd be accessible t gvernment authrities accrding t the laws that gvern thse jurisdictins. There are als ccasins when we prvide Persnal Infrmatin t ther cmpanies r ther entities, such as gvernment agencies, credit bureaus and cllectin agencies, withut yur cnsent. Sme examples include sharing t: Cmply with curt rders, subpenas, lawful discvery requests and ther legal r regulatry requirements, and t enfrce ur legal rights r defend against legal claims; Obtain payment r make refunds fr prducts and services that appear n yur SNC billing statements, including the transfer r sale f delinquent accunts r refund bligatins t third parties fr cllectin r payment; Enfrce ur agreements and prtect ur rights r prperty, Assist with identity verificatin and address validatin; Ntify, respnd r prvide infrmatin (including lcatin infrmatin) t a respnsible gvernmental entity in emergency r exigent circumstances r in situatins invlving immediate danger f death r serius physical injury; and Ntify the Natinal Center fr Missing and Explited Children f infrmatin cncerning child prngraphy f which we becme aware thrugh the prvisin f ur services. 5. D yu share my persnally identifiable TV viewing infrmatin with ther cmpanies? We dn't share yur persnally identifiable TV infrmatin with ther cmpanies fr them t use fr the marketing f their wn prducts and services withut yur cnsent. We are required t ntify yu abut the special requirements we must fllw when it cmes t sharing yur persnally identifiable TV infrmatin in respnse t a Curt Order. MY INFORMATION & ADVERTISING 1. D yu use my infrmatin t send me advertising? Yes. We may use infrmatin like the preferences yu have expressed and interests yu have demnstrated n ur websites, in ur stres and thrugh use f ur prducts and services, t prvide yu with marketing infrmatin and advertisements fr SNC prducts and services. Thse ads may be delivered n ur websites and mbile applicatins. This is called "first party" advertising. It is part f ur service relatinship and yu are nt able t pt-ut frm this type f advertising.

9 Our advertising affiliate and advertising partners may als use annymus infrmatin gathered thrugh ckies and similar technlgies, as well as ther annymus and aggregate infrmatin that either f us may have t help us tailr the ads yu see n nn- SNC sites. Fr example, if yu see an ad frm us n a nn-snc sprts-related website, yu may later receive an ad fr sprting equipment delivered by us n a different website. This is called "nline behaviral advertising," which is a type f Relevant Advertising. 2. D yu use my infrmatin fr ther types f Relevant Advertising? Yes. We als uses infrmatin we get thrugh yur use f ur prducts and services, frm ur advertising partners, and infrmatin like yur age and gender t deliver Relevant Advertising that is nt nline behaviral advertising. We cmbine yur annymus infrmatin with that f ther users int aggregate "audience segments." These segments are based n particular interests and/r factual characteristics that everyne in that audience segment is likely t share. We might use that infrmatin t send yu advertisements that are relevant t thse interests r characteristics. We are careful t create Relevant Advertising with aggregate audience segments that are large enugh that yu can't be identified individually. 3. D yu use the lcatin f my device fr advertising purpses? Yes. We use infrmatin abut the lcatins yu visit in rder t create cmbined wireless lcatin interest characteristics that can be used t prvide Relevant Advertising t yu and thers like yu. Lcatin characteristics are types f lcatins - like "mvie theaters." Peple wh live in a particular gegraphic area (a city, ZIP-cde r ZIP+ 4 cde, fr example) might appear t have a high interest in mvies, thanks t cllective infrmatin that shws wireless devices frm that area are ften lcated in the vicinity f mvie theaters. We might create a "mvies characteristic" fr that area, and deliver mvie ads t the peple wh live there. We may assciate yur wireless device with a particular gegraphic area, such as a city, ZIP-cde, r ZIP + 4 cde, based n yur billing address r the cell twers yu cnnect with mst frequently. We d nt keep a recrd f the places yu have visited. In additin t ther privacy prtectins, the prcess we use t create ur audience segment includes a requirement that the ZIP + 4 r ther gegraphic area t which a wireless lcatin is assigned must cntain a minimum f 25 husehlds. ZIP + 4 cdes with less than 25 husehlds are cmbined with ther ZIP + 4 cdes t satisfy this requirement. 4. What's in it fr me? Just like the name says, yu get advertising that's mre relevant t yur interests. Fr example, if a particular audience segment, like adults between the ages f 21 and 25 with a certain incme range, has demnstrated a greater interest in mvies than ther segments, we might send them a mvie ad fr a mvie geared tward yung adults. This is just ne way we deliver cntent that's mre relevant. 5. Hw d yu use infrmatin abut the prgrams I watch n SNC TV t advertise t me?

10 We cmbine infrmatin abut the shws that ur custmers are watching with their cmmn interests t help us figure ut what types f advertising they might be interested in seeing. It smetimes wrks like this: We lk at the grup f peple watching a particular shw. We identify cmmn characteristics within that grup. We use thse characteristics t identify and deliver advertising that might be mst relevant t watchers f that TV shw. We might als deliver that same advertising during shws that appear t have similar audiences. 6. D I ever have a chance t tell yu what I'm persnally interested in? When we add new ffers r alerts we'll let yu knw, s yu can decide if yu'd like t participate. Fr example, we may ffer yu free r discunted services in exchange fr the use f yur Persnal Infrmatin fr advertising and ther similar purpses. We prmise, befre we use any f yur Persnal Infrmatin (including infrmatin we gather as an Internet service prvider) fr such purpses, we will always give yu the pprtunity t make an infrmed chice abut whether t participate 7. What infrmatin d yu prvide t advertisers? We may prvide reprts t advertisers and ther business custmers abut the success f its advertising campaigns. Thse reprts cntain aggregate infrmatin abut the number f times a particular ad was viewed, when it was viewed, whether it was viewed n a TV, a mbile device r a cmputer, demgraphics assciated with the viewing audience and ther similar infrmatin. Yur annymus infrmatin will nt be included in aggregate reprts abut the success f Relevant Advertising campaigns if yu have pted-ut f Relevant Advertising delivered by us. LOCATION INFORMATION 1. What is lcatin infrmatin? Exactly what it sunds like! It includes yur ZIP-cde and street address, as well as the whereabuts f yur wireless device. 2. Hw is it used? We use it in all kinds f ways, here are sme examples: We Prvide Wireless Vice and Data Services: We mnitr, cllect and use wireless lcatin infrmatin, tgether with ther infrmatin we get frm ur netwrk and yur wireless device, t maintain and imprve ur netwrk. We als might use lcatin infrmatin with yur cnsent t prvide yu with a custmized experience. Fr example, when yu dial 411 Directry Assistance fr a business telephne number, we might use yur wireless lcatin infrmatin t return the number f the business lcatin clsest t yu. Lcatin Based Services (LBS): Yur device can be used t access a tn f services based n lcatin. We ffer these services via applicatins that have been pre-laded r dwnladed by yu n yur device. LBS als may be prvided via text message r ther functinality. We ll give yu prir ntice and ask fr yur cnsent when yur lcatin is used r shared. The frm f cnsent may vary, but will be apprpriate fr the type f LBS yu use.

11 LBS frm ther prviders: With yur cnsent (t us r the ther cmpany) we als may enable LBS frm ther cmpanies by prviding lcatin infrmatin t their develpers r lcatin service prviders. We use it fr Advertising. 3. Hw accurate is wireless lcatin infrmatin? It depends n the technlgy we're using. Fr example, we can lcate yur device based n the cell twer that's serving yu. The range culd be up t 1,000 meters in any directin frm the twer in urban areas, and up t 10,000 meters in rural areas. Wi-Fi netwrks prvide mre accurate lcatin infrmatin, assciating yu with the place where the netwrk is lcated - like a cffee shp - r t an area within r arund that place. Services such as 411, 911, a "friend lcatr" applicatin r a navigatin/mapping applicatin, require mre precise infrmatin. S fr thse we develp a mre precise estimate f lcatin by assciating the serving cell twer ID with ther infrmatin, like the latitude and lngitude f the twer, radi frequency parameters, GPS infrmatin and timing differences in radi signals. Depending n a variety f factrs, thse methds may estimate the lcatin f yur device t within 30 t 1000 meters. 4. Are yu the nly nes wh can lcate my wireless device? Other cmpanies may als be able t lcate yur device. Fr example, yur handset manufacturer and yur perating system prvider may be able t lcate yur device. If yu dwnlad mbile applicatins, thse apps may be able t btain yur lcatin directly frm yur handset r the perating system. Mbile applicatins that give yu access t yur emplyer's netwrk may als give yur emplyer the ability t lcate yur device. We urge yu t review Plicies f all prviders. AGGREGATE AND ANONYMOUS INFORMATION 1. Where d yu get annymus infrmatin? Smetimes we'll cllect infrmatin abut hw yu use ur prducts using ckies and ther similar technlgies. This infrmatin desn't include yur Persnal Infrmatin and is cnsidered annymus. When we cllect infrmatin that identifies yu persnally, we may annymize it fr certain purpses. We remve data fields (such as name, address and telephne number) that can reasnably be used t identify yu. We als use a variety f statistical techniques and peratinal cntrls t annymize data. Annymizing infrmatin is ne f the tls we use t prtect yur privacy. 2. Tell me mre abut aggregate infrmatin. Aggregate infrmatin is a frm f annymus infrmatin. We cmbine data that meet certain criteria int annymus grups. Fr example, we might want t cmpare hw custmers in Beverly Hills, CA (r any city, cunty r ZIP-cde) use their cell phnes t hw custmers in Bulder, CO use their cell phnes. In rder t d that, we wuld

12 cmbine custmer data in each f the gegraphies int annymus grups and lk at all that aggregate data t understand hw the tw grups are different r similar. 3. D yu share annymus r aggregate infrmatin? Yes, we may share this infrmatin with ther cmpanies and entities fr specific uses, which may include: Universities, labratries, think tanks and ther entities that cnduct netwrking, scial, behaviral, envirnmental and ther types f scientific research, fr the purpse f creating fundamental new knwledge; Municipalities, gvernment r ther entities that may use this data fr purpses such as municipal and transprtatin planning, and emergency and disaster respnse crdinatin. We share this infrmatin in external reprts like ur External Marketing & Analytics Reprts and Metric Reprts. EXTERNAL MARKETING AND ANALYTICS REPORTS 1. Tell me mre abut the External Marketing & Analytics Prgram. We use aggregate infrmatin t create External Marketing & Analytics Reprts that we may sell t ther cmpanies fr their wn marketing, advertising r ther similar uses. These reprts may be a cmbinatin f infrmatin frm wireless and Wi-Fi lcatins, website brwsing and mbile applicatin usage and ther infrmatin we have abut yu and ther custmers. Yu have a chice abut whether yur annymus infrmatin is included in these reprts. Sme examples f External Marketing & Analytics Reprts include: Reprts fr retail businesses that shw the number f wireless devices in r near their stre lcatins by time f day and day f the week, tgether with demgraphic characteristics f the users (such as age and gender) in thse grups. Reprts that cmbine annymus TV viewing behavirs with ther aggregate infrmatin we may have abut ur subscribers t create reprts that wuld help a TV netwrk better understand the audiences that are viewing their prgrams, thse that are nt, hw frequently they watch, when they watch and ther similar infrmatin; and Reprts fr device manufacturers that cmbine infrmatin such as device type, make and mdel with demgraphic and reginal lcatin infrmatin t reflect the ppularity f particular device types with varius custmer segments. 2. D yu prvide cmpanies with individual annymus data as part f yur External Marketing & Analytics Prgram? Yes. Fr example, we might share annymus TV viewing infrmatin with media research cmpanies that cmbine this data with ther infrmatin t prvide audience analysis services abut what shws certain audience segments are watching. When we prvide individual annymus infrmatin t businesses, we require that they nly use it t prvide aggregate reprts, and fr n ther purpse. We als require businesses t

13 agree they will nt attempt t identify any persn using this infrmatin, and that they will handle it in a secure manner, cnsistent with this Plicy. 3. D yu use my annymus infrmatin in ther types f external reprts? Yes, we may use yur annymus infrmatin t prvide Metrics Reprts t ur business custmers and service suppliers. These reprts are cnsidered part f the underlying service and we d nt sell them t ther custmers r suppliers. Fr example, if yu cnnect t ur Wi-Fi service in a htel, airprt r ther venue yu shuld knw the peratr f that venue is ur business custmer, and that we will prvide that peratr with Metrics Reprts abut usage f and cmmunicatins with the Wi-Fi netwrk in their lcatin. Thse reprts cntain statistical infrmatin like: The number f devices cnnecting t the Wi-Fi netwrk, duratin f Wi-Fi sessins and the amunt f bandwidth used during thse sessins; and Ft-traffic data, including the numbers f devices inside and utside the stre at a given time; the number f new and frequent visitrs; where visitrs are lcated within the stre (e.g., specific departments r ther lcatins within the venue) and frequency f visits and time spent within the stre. NOTE: When yur wireless device is turned n, it regularly sends ut signals that enable it t cnnect t cell twers, Wi-Fi access pints r ther technlgies s that we (and thers) are able t prvide yu with services. These signals can be used t determine yur device lcatin. Yu can turn Wi-Fi t the "ff" psitin n the "settings" feature f yur device t prevent the cllectin f these signals by Wi-Fi equipment in retail stres and ther public places. Anther example, we als license vide prgramming frm cntent prviders. As part f ur agreement, we prvide them with Metrics Reprts. These reprts cntain cmbined measurements and statistical infrmatin related t the number f TV subscribers wh watched r accessed a particular prgram at a particular time and ther similar measurements. ONLINE PRIVACY POLICY FOR CHILDREN 1. D yu cllect infrmatin abut my children's use? We d nt knwingly cllect persnally identifying infrmatin frm anyne under the age f 13 unless we first btain permissin frm the child's parent r legal guardian. 2. What happens when my child is using an accunt nt registered t them? Internet and wireless devices and services purchased fr family use may be used by children withut ur knwledge. When that happens, infrmatin cllected may appear t us t be assciated with the adult custmer wh subscribes t ur services and will be treated as the adult's infrmatin under this Plicy. 3. What can I d t help better prtect my child's infrmatin? We encurage yu t spend time nline with yur children, and t participate in and mnitr their nline activity. We have develped a website that ffers safety and cntrl tls, expert resurces and tips designed t help yu manage technlgy chices and address safety cncerns. Please visit fr mre infrmatin.

14 4. What if my child has an SNC sub-accunt? If yu create a sub-accunt fr a child under the age f 13: With yur permissin we cllect yur child s name, nicknames and aliases, alternative address, birth date, gender and ZIP-cde. We use the infrmatin cllected n sub-accunts t create and maintain thse accunts, fr research, t custmize the advertising and cntent seen n ur pages and fr ther marketing purpses. Yur child can use their address and passwrd t lg nt websites and nline services prvided by us r thers. We and ur advertising partners may cllect and use infrmatin abut custmers wh lg nt thse sites. A list f the advertising partners wh cllect infrmatin n ur sites and the ability t pt-ut f advertising prvided by thse partners is available We will nt cntact a child under the age f 13 abut special ffers r fr marketing purpses withut parental cnsent. Yu r yur child can review, edit, update, and delete infrmatin relating t yur child's sub-accunt and, if yu n lnger wish yur child t have such an accunt, yu can revke yur cnsent at any time, by lgging n t manage yur accunt Yu may us at snc@sentc.net, call us at r write t us at SNC, 110 West 17 th Street, Falls City, NE with any questins r cncerns yu may have abut ur Children's Online Privacy Plicy. QUESTIONS ABOUT DATA PROTECTION AND SECURITY 1. D we sell yur Persnal Infrmatin? N. We d nt sell yur Persnal Infrmatin t anyne, fr any purpse. Perid. 2. Hw lng d we keep yur Persnal Infrmatin? We keep yur Persnal Infrmatin as lng as we need fr business, tax r legal purpses. After that, we destry it by making it unreadable r undecipherable. 3. What safeguards des SNC have in place? We've wrked hard t prtect yur infrmatin. And we've established electrnic and administrative safeguards designed t make the infrmatin we cllect secure. Sme examples f thse safeguards include: All f ur emplyees are subject t the SNC cde f cnduct and certain statemandated cdes f cnduct. Under the COBC, all emplyees must fllw the laws, rules, regulatins, curt and/r administrative rders that apply t ur business - including, specifically, the legal requirements and cmpany plicies surrunding the privacy f cmmunicatins and the security and privacy f yur recrds. We take this seriusly, and any f ur emplyees wh fail t meet the standards we've set in the COBC are subject t disciplinary actin. That includes dismissal. We've implemented technlgy and security features and strict plicy guidelines t safeguard the privacy f yur Persnal Infrmatin. Sme examples are:

15 Maintaining and prtecting the security f cmputer strage and netwrk equipment, and ur security prcedures require emplyee user names and passwrds t access sensitive data; Applying encryptin r ther apprpriate security cntrls t prtect Persnal Infrmatin when stred r transmitted by us; Limiting access t Persnal Infrmatin t nly thse with jbs requiring such access; and Requiring caller/nline authenticatin befre prviding Accunt Infrmatin s that nly yu r smene wh knws yur Accunt Infrmatin will be able t access r change the infrmatin. Althugh we strive t keep yur Persnal Infrmatin secure, n security measures are perfect, and we cannt guarantee that yur Persnal Infrmatin will never be disclsed in a manner incnsistent with this Plicy (fr example, as the result f unauthrized acts by third parties that vilate the law r this Plicy). 4. Will yu ntify me in case f a security breach? Yes. We will make reasnable attempts t ntify yu if we determine that we have experienced a security breach and there is a reasnably likely risk f identity theft, r where therwise required by law. 5. Can I review and crrect my Persnal Infrmatin? Yes. We are happy t help yu review and crrect the Persnal Infrmatin we have assciated with yur accunt and billing recrds. Please cntact us. QUESTIONS ABOUT FUTURE CHANGES 1. What happens if there is a change in crprate wnership? Infrmatin abut ur custmers and users, including Persnal Infrmatin, may be shared and transferred as part f any merger, acquisitin, sale f cmpany assets r transitin f service t anther prvider. This als applies in the unlikely event f an inslvency, bankruptcy r receivership in which custmer and user recrds wuld be transferred t anther entity as a result f such a prceeding. 2. Will I be ntified if there are changes t this plicy? We may update this Privacy Plicy as necessary t reflect changes we make and t satisfy legal requirements. We will pst a prminent ntice f the change n ur websites. We will prvide yu with ther apprpriate ntice f imprtant changes at least 30 days befre the effective date. YOUR CHOICES & CONTROLS 1. Yu can chse nt t receive sme types f advertising nline r n yur wireless device. Opt-ut f all Relevant Advertising delivered by SNC nline and n yur mbile device Yu'll need t pt-ut n each cmputer brwser and mbile device yu want t exclude.

16 Opt-ut f nline behaviral advertising prvided by us and ther advertisers by clicking the link at the bttm f ur web pages. Opt-ut f interest-based advertising n the web. Opt-ut f nline behaviral advertising frm many ther ad netwrks at the Netwrk Advertising Initiative (NAI) site. T limit cllectin f data n web sites that may be used fr advertising, g manage yur accunt n ur web site (link t web site here) fr infrmatin n hw t manage ckies and ther similar technlgies n yur cmputer. 2. D I have chices abut receiving first party advertisements frm SNC? Because first party advertising is part f the service yu receive when yu visit ur websites and use ur mbile applicatins, we dn't ffer an pt-ut fr first party advertising. 3. Yu can als chse nt t receive ther types f marketing frm SNC. We realize that unwanted marketing cntacts can be a hassle and we've wrked hard t meet the expectatins f custmers and ptential custmers wh have expressed a desire t limit certain types f slicitatin cmmunicatins frm us. Every marketing we send cntains instructins and a link that will allw yu t stp additinal marketing s fr that prduct r service type. Yu als can unsubscribe frm SNC marketing s Cnsumer Telemarketing: Ask t be remved frm ur cnsumer telemarketing lists by cntacting us at Yu als can ask the SNC representative t remve yu frm ur telemarketing lists when yu receive a marketing r prmtinal call frm us. Business Telemarketing: Where required by state laws and/r regulatins, we hnr requests t be remved frm ur telemarketing lists frm business custmers. Federal D Nt Call: The FTC maintains a Natinal D Nt Call Registry at dntcall.gv, and yur state may maintain its wn D Nt Call Registry. Putting yur number n these Registries als may limit ur telemarketing calls t that number. Pstal Mail: T review ur Residential D Nt Mail Plicy Statement and t limit pstal mail slicitatins, click Yu will still receive billing statements, legal ntices, prduct updates and ther similar crrespndence, and yu may still receive sme prmtinal mailings. All f ur practices are designed t satisfy state and federal legal requirements limiting marketing cntacts. Thse laws and regulatins - such as the requirements gverning the state and federal "D Nt Call" lists - generally permit cmpanies t cntact their wn current and, in sme cases, frmer custmers, even when thse custmers are listed n the federal and state "D Nt Call" lists. Restricting ur use f yur CPNI will nt eliminate all types f ur marketing cntacts. 4. Can I chse t exclude my annymus infrmatin frm yur External Marketing & Analytics and ther similar reprts?

17 Yes. Click t pt-ut. This pt-ut als applies t the sharing f yur annymus infrmatin with ther cmpanies fr their use in creating marketing and analytics reprts. Althugh this pt ut des nt apply t Metrics Reprts, it will apply if we cmbine Metrics Reprt infrmatin with ther custmer infrmatin (like demgraphics) t create reprts that we prvide t ur business custmers r service suppliers. 5. Are there any ther pt-ut chices I shuld knw abut? We may use services prvided by analytics cmpanies t btain infrmatin abut website perfrmance and hw yu use ur mbile applicatins and ther prducts and services. G t fr mre infrmatin abut the pt-uts made available by sme f thse vendrs, and t make chices abut participatin. 6. These Chices and Cntrls als are available at HOW TO CONTACT US ABOUT THIS POLICY We encurage yu t cntact us directly at either f these addresses belw fr any questins abut this Privacy Plicy. us at snc@sentc.net Write t us at SNC, 110 West 17 th Street, Falls City, NE Fr questins nt related t privacy click n the "Cntact Us" link at the upper right hand crner f Yu als can access yur nline accunt frm ur hme page at fr additinal service ptins. If yu d nt receive acknwledgment f yur privacy inquiry r yur inquiry is nt addressed t yur satisfactin, yu may cntact the FTC Bureau f Cnsumer Prtectin, using an (FTC web address here) r by calling tll-free 877.FTC.HELP ( ; TTY: ). Other rights and remedies als may be available t yu under federal r ther applicable laws. Custmer Prprietary Netwrk Infrmatin (CPNI) What is CPNI? Custmer Prprietary Netwrk Infrmatin (CPNI) is infrmatin that SNC and ther telecmmunicatins carriers btain when prviding yur telecmmunicatins services t yu. CPNI includes the types f telecmmunicatins services yu currently purchase, hw yu use them, and the billing infrmatin related t thse services, including items such as the types f lcal, lng distance and wireless telecmmunicatins services that yu have purchased and yur calling details. Yur telephne number, name and address are nt cnsidered CPNI. Use and Disclsure f CPNI We use yur CPNI t ffer yu additinal services f the type yu already purchase frm SNC. We als may use yur CPNI t ffer yu prducts and services, packages, discunts and

18 prmtins frm ur subsidiaries and business partners such as High Speed DSL Internet access, wireless service and TV services, which may be different frm the types f services yu already purchase. SNC uses technlgy and security features and strict plicy guidelines t safeguard the privacy f CPNI and prtect it frm unauthrized access r imprper use. SNC des nt disclse CPNI utside f the SNC cmpanies r their agents withut custmer cnsent except as required r allwed by law. When SNC uses third parties t perfrm services n its behalf that require the use f CPNI, SNC requires that they prtect CPNI cnsistent with this privacy plicy. SNC des nt sell CPNI t unaffiliated third parties. Restricting ur use f yur CPNI If yu wish t restrict ur use f yur CPNI fr marketing purpses, yu may cntact a custmer service representative at the custmer service phne number lcated n yur SNC telephne bill r ne f the fllwing numbers: Business Restricting ur use f yur CPNI fr marketing purpses will nt affect the prvisin f any SNC prducts r services t which yu subscribe, nr will it eliminate all types f SNC marketing cntacts. Custmer Service Cntact Numbers Business Residential