- What personally identifiable information of yours is collected;
- Who is collecting the information;
- How the information is used;
- With whom the information may be shared;
- What choices are available regarding collection, use and distribution of the information;
- How we protect the information; and
- How you can delete or correct any inaccuracies in the information.
I. Collection of Information
A. What Information We Collect
CaptionCall may collect information about you, your use of our products and services, and our business relationship with you.
We may collect personally identifiable information (“PII” or “Personal Information”), meaning information that can be used to identify or contact you. Examples include your name, address and telephone number. CaptionCall generally collects Personal Information in two ways: (1) when you choose to use, apply for, or register for a service or product offered by CaptionCall, or (2) when you choose to send an e‐mail to, participate in surveys, or engage in other transactions or interactions with CaptionCall.
Some examples of the type of information we may collect are:
CaptionCall may implement location‐based services in the future. If you elect to use those services, we may collect information about and monitor your location information. If you use our location‐enabled services other than for 911 calls, we may collect information about your location from those services or your device.
We also may collect non‐personally identifiable information (“non‐PII” or “Non‐Personal Information”) about your use of our products and services and our business relationship with you when you interact with or use our Web site, products or services, or respond to e‐mails, newsletters or promotional or other informational communications. Information that does not reveal how to identify or contact a user is non‐PII. For example, “aggregated data,” such as the number of visitors who access the CaptionCall website on a particular day or the percentage of users who download CaptionCall services, is non‐PII.
B. How We Collect Information
We may collect Personal or Non‐Personal Information when you interact with our products or services. For example, in order to have access to certain CaptionCall products and services, you may give us PII or non‐PII when you interact with us about the products or services, complete an application or other registration form(s), or provide other information reasonably necessary for us to provide the products and/or services we offer or provide to you.
We may collect Personal Information and Non‐Personal Information automatically when you visit our websites or use our products and services.
C. How We Use Information
We use the information we collect to provide you with our products and services and to respond to your questions. We also use it to provide a better customer experience and to continue improving the quality of our products and services. We may use Personal and Non‐Personal Information to communicate with you about our services. This may include sending you updates, promotions, and special offers, as well as content or advertising that may be of interest to you. We also use the information we collect to ensure that our products, services and website remain functioning and secure, or to investigate, prevent or act on any illegal activities or violations of our Service and Product Agreements.
CaptionCall will access, use, share or disclose your Personal Information, subject to applicable legal restrictions, such as those that apply to Customer Proprietary Network Information (“CPNI”), under the following limited circumstances.
First, we may access, use, share or disclose your Personal Information if reasonably necessary to:
- Initiate or provide CaptionCall products or services;
- Comply with legal requirements such as a law, regulation, search warrant, subpoena or court order;
- Respond to 911 calls or other emergencies;
- Enforce applicable provisions of CaptionCall's Service and Product Agreements (available at CaptionCall EULA) including investigation of potential violations;
- Detect, prevent, or otherwise address fraud, identity theft, security or other technical issues; or
- Protect the rights, property or safety of CaptionCall, our employees or users, or the public as required or permitted by law.
Second, CaptionCall may use your Personal Information for research and analysis in order to improve our products, website and services.
Fourth, in the event that CaptionCall undergoes a business transition or change in corporate structure, such as a merger, acquisition, or sale of a portion of its assets, users’ Personal Information may become part of the assets transferred. We may choose in such instances to disclose Personal Information and Non‐Personal Information about you, the consumer, to a third party for compensation.
Fifth, in order to provide our services, we may occasionally provide information to other companies or independent contractors that work on our behalf.
Sixth, we will share some or all of your information (and in the case of minors, the information of both the minor user and the parent) with third parties as required or permitted by law or regulation, including with government agencies and private entities responsible for overseeing or administering the Telecommunications Relay Fund and verifying eligibility for IP CTS services. For example, CaptionCall will submit CaptionCall users’ information to the TRS User Registration Database, a database administered by a government contractor, as required by FCC regulations, and CaptionCall will submit information about CaptionCall users and their TRS usage to the Administrator of the TRS Fund and/or the FCC for billing purposes.
Finally, information that does not reveal how to identify or contact a user is not Personally Identifiable
Information. For example, “aggregated data,” such as the number of visitors who access CaptionCall's Web site on a particular day or the percentage of users who download services from CaptionCall, does not constitute Personal Information under this Policy.
Notwithstanding any other provision of this Agreement, to the extent you use CaptionCall to place a telecommunications relay service call (CaptionCall is a form of telecommunications relay service), your privacy rights and CaptionCall’s obligations with regard to any information generated by that call shall be governed by applicable law, including relevant sections of the Communications Act of 1934, as amended, and any applicable implementation rules and orders.
D. Links to Other Web Sites
E. E‐mails or Other Communications
F. Advertising Partners
After providing you with appropriate notice and with your permission, we may use your Personal Information to send you advertisements, promotions, offers, and other informational communications that may be of interest to you on behalf of advertising partners. We may provide those partners with reports about the kinds of people seeing their ads or how their ads are performing, but we will not share, disclose, or permit access to any of your Personal Information, including your CPNI.
II. Online Privacy for Children
We do not knowingly collect Personal Information over the Internet from anyone under the age of 13 unless we first obtain permission from that child’s parent or legal guardian. After we receive your permission as a parent or legal guardian, we will only collect, store, and disclose information necessary to provide IP CTS products and services to your child.
When you apply for IP CTS products and services on behalf of your child under the age of 13, we may collect the following information about your child:
- Last four digits of social security number
- Email address
- Date of birth
- Phone number associated with the CaptionCall account
- Eligibility information for deaf and hard‐of‐hearing individuals
- Connectivity information, such as information about your child’s internet connection
- Name, email address, and phone number of parent or guardian
After we receive your permission to provide IP CTS product(s) and service(s) to your child, we will collect, store, and disclose information necessary to provide those IP CTS products and services to your child. When providing IP CTS products and services, CaptionCall (or a company that CaptionCall uses to help provide IP CTS products and services) may collect and store:
- Unique identifiers associated with your child’s phone or mobile device, such as a telephone number, IP address, or MAC address
- The length of each call, for accounting purposes
- Your child’s contact lists, to allow your child to maintain and use those contact lists
- Information necessary to complete or receive a call, including information about who your child is calling or who is calling your child
- Information about your child’s use of the CaptionCall website
CaptionCall may disclose or provide access to this information to third parties for the purpose of providing your child with IP CTS products and services, for billing and administrative purposes and otherwise, as required or permitted by law or regulation, including with government agencies and private entities responsible for administering or overseeing the Telecommunications Relay Service Fund and verifying eligibility for IP CTS services. For example, CaptionCall may submit your and your child’s information to the TRS User Registration Database, a database administered by a government contractor, as required by FCC regulations, and CaptionCall will submit information about your and your child’s TRS usage to the Administrator of the TRS Fund and/or the FCC for billing purposes.
CaptionCall may also share information about your child’s location with emergency services if your child calls 911 from a CaptionCall mobile device.
If your child uses CaptionCall products and services from a mobile device and enables location information on that device, CaptionCall may share your child’s precise location information with third parties. However, we do not knowingly allow children under 13 to enable sharing of location information without parental consent. CaptionCall does not otherwise disclose any of this information to third parties unless required by law.
Before establishing service for a child under 13, we will provide a parent or guardian a notice of our privacy practices in person, ask whether you consent to these practices, and have you verify your identity by showing a valid, government‐issued form of identification.
You have the right to ask CaptionCall at any time to allow you to review the information CaptionCall has collected about your child under the age of 13, to stop collecting personal information about your child, or to delete information it has on file about your child that CaptionCall is not legally obligated to retain. We may be legally obligated to honor your request if your child is under 13, or an older age in certain states. We may choose to honor reasonable parental requests to control their children’s Personal Information, even when the law does not require us to do so; however, we have sole discretion over granting such requests.
If you have further questions or requests related to CaptionCall’s online collection of information from children, please contact us at:
IV. Updating or Deleting Your Personal Information and Preferences
You can contact us in order to (1) delete your Personal Information from our systems, (2) update the Personal Information that you have provided to us, or (3) change your preferences with respect to marketing contacts or other activities, by e‐mailing us at firstname.lastname@example.org. We will make good faith efforts to accommodate such requests, and we have a duty to honor your decision regarding the use, disclosure, or access to CPNI, unless such information is needed to comply with valid legal requirements or to protect the rights, property or safety of CaptionCall, our employees or users, or the public. In your request, please provide your name, email address or other contract information, and describe the information requested to be accessed, corrected, or removed, or the preference to be changed in any such request. We may decline to process requests that are unreasonably repetitive or complicated, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical. Because of the way we maintain certain services, including backup systems, even after we delete your information, copies may remain on our servers and systems for a period of time before being deleted. Any requested changes will not have any effect on the service that we provide to you or other information that we maintain.
at email@example.com, and the customer service department will forward your complaint to the appropriate CaptionCall department for a response or resolution. We try to answer every e‐mail in a timely manner, but please be aware that some requests may take longer than others.