Policy & Rules Regarding Telecommunications Services
The two primary federal rules that address the safeguarding of a customer’s right to confidentiality relative to telecommunications service are:
- the Federal Communications Commission’s (FCC’s) Customer Proprietary Network Information (CPNI) rules; and
- the joint Federal Trade Commission’s (FTC’s) and other agencies Red Flag Rules.
Although the CPNI rules and Red Flag Rules are separate and distinct and issued by different federal regulatory authorities, the rules complement each other. The CPNI rules, originally designed to safeguard certain customer information from being shared for marketing purposes, were eventually revised to include provisions to safeguard each customer’s call detail records from being obtained through pretexting (unauthorized access to records by a person pretending to be the customer or the customer’s duly authorized agent). While the CPNI rules address pretexting, which is one form of identity theft, the Red Flag Rules are broader and address all forms of identity theft. This document addresses the Company’s policy regarding prevention of identity theft in accordance with the Red Flag Rules.
Customer Proprietary Network Information (CPNI)
In providing services to you, Whidbey Telecom may collect certain information that has been made available to us by virtue of our relationship with you, as our customer. Some of this information includes details of the telecommunication services you purchase from us, including technical configuration and amount of use of those services. This information can also be information included on your telephone bill related to services you’ve purchased, including long distance call detail information.
The Federal government has defined this information as Customer Proprietary Network Information (CPNI). Federal rules and regulations of the Federal Communications Commission (“FCC”) require telecommunications carriers to verify the identity and appropriate authorization of anyone requesting access to certain customer account information (also known as CPNI). Whidbey Telecom considers customer account information to be confidential including any information classified as CPNI. CPNI does not include Subscriber List information.
Information You Provide to Whidbey Telecom
In our continued commitment to safeguarding our customer account information and in alignment with these federal rules, Whidbey Telecom has established the following procedures when we collect information on your behalf.
- When you visit one of Whidbey Telecom’s Customer Service Centers, you will need to present a valid government-issued photo ID. Whidbey Telecom will review the account information to verify the name of the requestor as having authorization to discuss the relevant account information or make changes to the account. The FCC does not allow for any exceptions to this rule. Even if our customers are known to us, we are still required to review photo ID in order to release account information and/or make changes to accounts.
- When you access your account information online, you’ll need to have an established Whidbey Telecom eBilling account with a specific online Username and Password. If you’d like to establish a Whidbey Telecom eBilling account, contact our Customer Experience Center for more information and assistance.
- When you call us, Whidbey Telecom will verify your name against the authorized name(s) listed in the relevant account record. You must then provide the correct, pre-established Subscriber Verification Code (SVC) or correct answers to the pre-established Security Questions listed in the relevant account record before we will proceed with discussing the subject account information.
If you call us to discuss long distance call information and you are verified as an authorized contact but unable to supply us with the correct SVC or answers to the back-up Security Questions, we may still be able to assist you with your request. If you have the call detail information that you’d like to discuss with you, we can discuss only the specific call detail information you provide to us during that call. We can also mail a copy of your invoice to either the postal or email address of record or call you back at the telephone service telephone number of record (either of which must have been on record for at least the past 30 days). If we call you back at the service telephone number of record, we will request you to verify other account information before supplying the requested call detail information.
Policy & Rules Regarding Targeted Advertising
Whidbey Telecom automatically collects certain information about your device and how your device interacts with our website for the purposes of targeted advertising. For example, analytics services, such as Google Analytics, may use tracking technologies on our website to help us analyze your use, compile statistic reports, and provide other services relating to website activity and usage.
The types of information we automatically collect include your device’s IP address and other device identifiers; the type of internet browser you are using on your device; the type of operating system application software and peripherals you are using on your device; the domain name of the website from which your device linked to our website, such as Google; and your browsing habits on and usage of our website through your device.
Information Collected Automatically
Unless you have opted-out or have otherwise refused to provide consent, the following is data that we collect from your device automatically:
- Cookies A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain various types of information, including a user ID that the site uses to track the pages you have visited.
- Location-identifying Technologies. Location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.
How We Use the Data We Collect
We generally use the data we collect to help us better identify your needs and engage with you. For example, when you supply your email address to Whidbey Telecom you are authorizing it to be added to your account records for future reference and as a method to contact you. We may use your email address to send you important notices regarding your account and to update you on Company news and promotions.
Our business purposes for collecting and using information include:
- To perform services requested by you, such as to respond to your comments, questions and requests, and provide customer service;
- To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
- To prevent and address fraud or breach of policies or terms;
- To monitor and analyze trends, usage, and activities for the purpose of improving our Marketing efforts;
- To improve Whidbey Telecom’s website, applications, and product services to better serve our Customers;
- To provide you with advertisements about our products, services, promotions, and events;
- To fulfill any other business or commercial purposes disclosed to you and with your consent.
- Vendors and Other Parties: We may share information with vendors and other parties for business and commercial purposes, including analytics and advertising technology companies.
Your Choices and Opting-Out
You may opt out of news and promotional emails at any time by replying to one of the emails with “Unsubscribe” in the subject line or by contacting our Customer Experience Team.
Analytics and Interest-Based Advertising
We recognize how important your online privacy is to you, so we offer the following options for controlling the interest-based ads you receive and how we use your data. Opting-out of this type of advertising will not prevent you from seeing ads, rather those ads will likely be less relevant. This is because they will not be tailored to your specific interests but will instead be based on the context of the Digital Property in which they are displayed.
Some actions you can take to control how we use this data include:
- Some of the parties that collect information from or about you on our website in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about the DAA and your opt-out options for their members, please visit the DAA website.
- Some of the above parties may be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, please visit the NAI website.
Please note that if you opt-out of online behavioral advertising using any of the above methods, the opt-out will only apply to the specific browser or device from which you opt-out. We are not responsible for effectiveness of, or compliance with, any other parties’ opt-out options or programs or the accuracy of their statements regarding their programs.