Privacy Policy

Effective March 21, 2022

 

Hyde Park West Telecommunications, LLC (“HPWT”, ”we”, or “us”) has created this Privacy Policy (“Privacy Policy”) to demonstrate our commitment to protecting the personal information of (a) users who access and use our website (“Website”), mobile applications, or online services, including offerings made available through our Website (collectively, the “Services”); (b) our existing and prospective clients, and their personnel, users and representatives; including Customers who purchase our products and services (collectively, “Products”); and (c) any other individuals from whom we collect personal information during the course of our business activities.

This Privacy Policy describes the personal information HPWT collects, how we use your personal information, with whom we may share such data, and how you can contact us, access your personal information and exercise your rights regarding our use of your personal information.  As used in this Privacy Policy, “personal information” means data that identifies, relates to, describes, or that could be linked to a particular identified or identifiable natural person or is otherwise considered personal information under applicable privacy and/or data protection laws or regulations. By using or accessing the Services or otherwise providing personal information to HPWT, you signify your acknowledgment and assent to this Privacy Policy, and consent to the collection, processing and use of your personal information as described. If you do not agree to this Privacy Policy or such terms, please do not use the Website, Products or Services or otherwise provide personal information to us.

  1. Changes to Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes to our information practices. If we make any material changes we will notify you using the contact information you have provided to us, via your account or the Services, or by means of posting an updated version of this Privacy Policy on the Website. We encourage you to periodically review our posted Privacy Policy for the latest information on our privacy practices. Any modifications to this Privacy Policy will be effective upon our posting or notification of the new terms, and your continued use of the Website, Products, Services, or our other products and services thereafter indicates acceptance of the modified Privacy Policy. If you do not agree to any part of a modified Privacy Policy, then you must terminate your account and stop accessing the Services, Products and Website and otherwise providing personal information. Specific areas or pages of the Services or Website may include additional or different provisions relating to collection and disclosure of personal information.  In the event of a conflict between such provisions and this Privacy Policy, such specific terms shall control.

  1. Collection of Personal Information

We may collect personal information from you directly such as from forms on the Website or Services; in connection with Product orders; from contracts, service applications, subscription agreements, or other agreements or forms you fill out; from individuals and/or entities whom you have authorized to act on your behalf and/or to provide information about you; from surveys; when you submit an inquiry to us; in connection with your transactions with us, our affiliates or Service Providers or others; or from other communications with us. In order to use certain parts of the Website, Products or Services, you may be required to set up an account with us (an “Account”). During this process, we may ask you for certain personal information to establish and use your Account. Where permissible by applicable law, we may also collect personal information from publicly available sources. The categories of personal information we collect may include:

  • Personal identifiers (e.g., name, unique personal identifier, online identifier, device identifier)
  • Contact information (e.g., mailing address, email address, phone number)
  • Personal characteristics (e.g., age, gender)
  • Demographic information (e.g., your preferences)
  • Financial data (e.g., payment and payment card information may be collected by Payment Processor – see Section 4)
  • Transaction data (e.g., products and services used, ordered or preferred)
  1. Collection of Usage Information

General data may be collected related to your use of the Website, Products and Services, including info about the mobile devices and programs which you use to access our offerings (“Usage Information"). Usage Information can include: the name of the domain and host from which you access the Internet; the Internet Protocol (IP) address of the device you are using; the browser software and operating system you are using; mobile device type, device operating system, device identifiers, device settings, the date and time of access (including the length of time spent, the pages accessed while visiting, links clicked, and number of visits, and country of origin); and the address of the website from which you have arrived at our Website or Services. This Usage Information is collected to help us manage and administer our Website, Services and systems, monitor and tailor our marketing activities, improve the content of our products and services, and customize and improve user experience. We may link Usage Information to personal information for Account holders. Usage Information is gathered using general detection and use of your internet protocol (IP) address, device identifiers, or domain name and the following methods:

  • Usage Information may be collected through the use of “cookies,” which are small text files that are saved by your browser or device that serve a number of purposes, such as remembering your preferences (e.g., language) and generally improving your user experience. We (and our Service Providers) may use both session cookies and persistent cookies to gather analytics about our Website and Services, including Usage Information and demographic information in a non-identifiable form, in order to monitor usage and traffic, improve performance and customize users’ experience. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of our Website or Services. This Privacy Policy covers the use of cookies by our Website but does not cover the use of cookies by any third parties associated with the Website or Services (including Analytics Services, Advertising Networks or other Third Party Services as discussed below in Section 8).  Such entities may employ cookies, device identifiers, or similar technologies to collect their own Usage Information regarding our Websites or Services and their usage of such information will be governed by the applicable third party’s privacy policy.
  • Tags/Beacons. Usage Information may be collected through the use of software technology called tags or web beacons (a.k.a. pixel tags or clear gifs) that help us better manage Website and Services content and communications by informing us what content is effective and how it is used. These beacons (or other tracking technology) may also be included in or associated with e-mails or other communications that you receive from us (or our Service Providers) in order to help us track your response and interests and to deliver you relevant content and services.
  • Location Data. When you use certain features of our Website, Products or Services, information about location may be collected, including general information (e.g., IP address, zip code), and more specific GPS location information that is provided to us by your device.
  1. Payment Processing

Payment card information (such as payment card name, card number, CVV and expiration date) may be collected at the time of a transaction. This information is required so that payment can be authorized by a third-party payment processor (the “Payment Processor”) that we have retained to process payments. All payment card information is provided directly to the Payment Processor and not to us (i.e., we do not receive or store your payment card information in connection with authorized payments). All internet transactions with the Payment Processor are performed on a server that uses industry standard encryption technology to help protect your payment card information from being obtained by unauthorized third parties. Your payment, and use of your payment and transaction information, will be subject to the privacy policies of the Payment Processor and your payment card issuer. We are not responsible for any actions or errors of the Payment Processor or for any security breaches suffered by such entity. In connection with your payments, we may obtain certain payment transaction details from the Payment Processor, which we will use solely in accordance with this Privacy Policy.

  1. Use and Processing of Personal information

We use and process your personal information for reasonable and legitimate business purposes, to perform and fulfill our contractual obligations to you, and to comply with legal obligations, including for the following purposes:

  • Contacting you regarding business transactions and information related to the products or services you have purchased or are using.
  • Providing our products and services to you (for example, if you provide us with personal information in order to place an order with us, we will use that information to process your payment, complete the sale and ship Product to you).
  • Informing you about our products and services and other promotional activities.
  • Responding to your comments or requests for information.
  • Contacting you regarding future opportunities and changes in our activities, products and services.
  • Performing business and administrative processes related to your Account or business relationship with us.
  • Developing, enhancing, and improving our products and services.

Administering and managing our relationship with you and/or providing on-going support to you.

  • Evaluating, reviewing, approving, or entering into transactions or potential contractual arrangements.
  • Enhancing the security of our network and information systems.
  • Monitoring how people interact with our Website, Products and Services, and optimizing our Website, Products and Services and customer experience.
  • Complying with our obligations under applicable law, industry guidelines and internal policies.
  • Monitoring and tracking our marketing activities and showing customized ads to you.
  • Enforcing any contracts that we enter into with you, or defending claims arising from such contracts.
  • As otherwise described to you when collecting your personal information.

We do not use your personal information without a lawful basis, or for purposes contrary to this Privacy Policy, without your consent.

  1. HPWT Communications

When you sign up to receive information from us or otherwise provide us with personal information, we may automatically place you on our list to receive communications and updates and offers regarding HPWT and our affiliates.  If you do not wish to receive these messages, you can simply utilize the opt-out method detailed in the message or contact us at the contact points specified below in Section 18. You may not opt-out of receiving essential updates regarding your relationship or transactions with us.

  1. Sharing of Personal Information

In connection with the purposes above, we may share your personal information with third parties in the following circumstances:

  • We may share your personal information with third-party companies that we have retained to perform services on our behalf (including delivery/logistics/fulfillment, web hosting, marketing, analytics, maintenance, administration, support, and database management services) (collectively, “Service Providers”). We do not authorize Service Providers to use your personal information except for the purpose of providing those services requested by us.
  • We may disclose your personal information to our corporate affiliates.
  • We may disclose your personal information to third parties whom you have authorized in connection with products and services we provide to you.
  • We may disclose your personal information as required (or requested by law enforcement) and permitted by law or regulation, including in response to a subpoena or to respond to an emergency situation.
  • We may disclose your personal information in limited circumstances to perform background checks in accordance with applicable law.
  • We reserve the right to disclose personal information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury or interference with (either intentionally or unintentionally) our rights or property or anyone else that could be harmed by such activities.
  • In the event HPWT or its affiliates or their assets are sold, merged or otherwise involved in a corporate transaction, your personal information will likely be transferred as part of that transaction – we reserve to right to transfer your personal information without your consent in such a situation; provided that we will make reasonable efforts to see that your privacy preferences are honored by the transferee.

 

Outside of the exceptions above, HPWT does not share your personal information with third parties unless you have specifically requested that information be released to them or have otherwise consented to such sharing. We do not provide personally identifiable information collected by this website to any third party for such third party’s direct marketing purposes.

  1. Interaction with Third-Party Platforms and Functionality

Certain features or aspects of our Website, Products or Services may be facilitated or provided by third party providers (“Third Party Services”), including features that collect Usage Information or generate performance metrics concerning our Website or Services, deliver advertising to you, or provide social media functionality.

  • Telecom Providers. Our Products and Services interact with existing cellular, Wi-Fi, internet, and satellite services offered by third-party telecommunications providers (such as GCI and Verizon Wireless®) (each, a “Telecom Provider”) to improve connectivity in areas of low bandwidth. Telecom Providers will have access to any data routed by our Products and/or Services through their wireless, wired or other telecommunication networks (“Telecom Services”). These Telecom Providers and Telecom Services may collect your personal information and track your use of our Website, Products or Services by collecting information through automated means including IP addresses, web server logs and other methods.   We are not responsible for the data collection or privacy polices of any Telecom Provider or Telecom Service, and have no control over the activities of any Telecom Provider.  We encourage you to periodically review the Privacy Policies of the relevant Telecom Providers that you use or authorize in connection with our Products and Services.
  • Third-Party Analytics. Our Websites or Services may rely on one or more third-party analytics services (“Analytics Services”) to evaluate, analyse and provide information and performance metrics regarding your use of the Website or Services. Analytics Services use cookies, tags and other technologies to collect and analyse Usage Information. The Analytics Services with whom we currently interact are the following: Google® Analytics. Analytics Services may change from time to time, please check this Privacy Policy periodically for the latest information.
  • Third-Party Advertising Networks. We may interact with third-party online advertising networks, social media companies and other third-party services, to evaluate and analyse information about your use of our Website and Services and other websites over time (“AdTech Services”) so that they may display ads on our Website or Services, on other devices you may use, and on other websites, apps or services, including on social media platforms. These AdTech Services may track your online activities over time and across our Website and other websites by collecting Usage Information through automated means, including through the use of cookies, IP addresses, web server logs, beacons/tags and other methods. The AdTech Services use this information to show you advertisements for us and other clients that are tailored to your individual interests. The information AdTech Services collect includes information about your visits to websites that participate in the providers’ advertising networks, such as the pages or advertisements you have viewed, and the actions you take. We may provide networks with pseudonymized or hashed customer lists to deliver ads to such customers and similar users on the applicable ad network. The AdTech Services with whom we currently work is the following: Google® Ads. AdTech Services may change from time to time, please check this Privacy Policy periodically for the latest information.
  • Conversion Tracking. We may use conversion tracking or other search engine or social media features that permit us to measure the effectiveness of search results or links and track resulting interaction with our Website or Services. These features use cookies, tags/beacons or other methods to collect Usage Information such as time of day, browser type, browser language, and IP address in connection with search queries or targeted links.
  • Third-Party Offerings and Social Media Functionality. Our Website and Services may enable you to connect to other external services and social media features such as the Facebook “like” button, widgets such as the “share this” button, and other social media functionality. These third-party sites and features may collect your personal information and track your use of our Website, Products or Services and other websites by collecting Usage Information through automated means, including through the use of cookies, web server logs, beacons/tags and other methods.

Your interaction with a Third Party Service may permit the Third Party Service provider to collect personal information or Usage Information or to track user activity. We are not responsible for the data collection or privacy polices of any Third Party Service, including their use of cookies or other tracking devices. By accessing and using the Websites, Products or Services, you consent to the collection and processing of Usage Information and data concerning you by Third Party Services. You can learn more about how Google uses data at https://policies.google.com/technologies/partner-sites, and find information regarding opt-out features that may let you opt out of Google’s use of your information for interest-based advertising purposes at https://adssettings.google.com.

  1. Use of Aggregate and Non-Personally Identifying Information

We may anonymize, pseudonymize, aggregate or de-personalize personal information and/or Usage Information to create non-personally identifiable information (“Anonymized Data”). We may freely disclose and use Anonymized Data and other non-personally-identifying information for industry analysis, statistical purposes, demographic profiling, marketing and advertising, and other business purposes (which may include reporting on trends in the usage of the Website or Services).

  1. Do Not Track

We do not collect personally identifiable information about an individual user’s online activities over time and across third party web sites, and therefore we do not currently employ a process for responding to “Do Not Track” (DNT) signals sent by web browsers, mobile devices, or other mechanisms. As noted in Section 8, Third Party Services (such as Analytics Services, AdTech Services, and social media platforms) may be able to collect information about your online activities over time and across different websites when you use our Websites, Products or Services. These entities may use this information to show you tailored ads and content. You may be able to opt out of or customize such tracking as further detailed in Section 8.

  1. Transfer of Personal Information

All personal information that you provide to us, including in connection with the Websites and Services, will be processed and maintained by us in the United States, and it may also be transferred by us to Service Providers within the United States or elsewhere (which may include countries outside of the European Economic Area).  By agreeing to this Privacy Policy, you consent to such transfer of your personal information.

  1. Retention of Personal Information

HPWT will retain your personal information for as long as your Account and/or our business relationship is active and as reasonably needed to maintain business records for audit purposes, meet regulatory requirements, defend or bring potential legal claims, and respond to post-termination inquiries. In addition, personal information may be retained for such additional time as may be required under applicable law, including record retention requirements. If you wish to request that we no longer use your personal information to provide you with products or services, contact us using the contact points specified below in Section 18.

  1. Security

We maintain appropriate physical, electronic and procedural safeguards and controls to help protect against the loss, misuse, alteration and unauthorized disclosure of personal information in our possession or under our control. While we use commercially reasonable efforts to safeguard the confidentiality of your personal information, we cannot guarantee that data will always remain secure due to transmission errors, outside events, third-party hacking or other causes. We will comply with all privacy laws and make any legally required disclosures regarding breaches of the security, confidentiality, or integrity of personal information consistent with our ability to determine the scope of a breach and our obligations to law enforcement.

  1. Policies for Children

We do not intentionally collect or use any personal information from users under 18 years of age. No data should be submitted to the Website or Services by users under 18 years of age.

  1. External Websites

The Website and the Services may contain links to third-party websites (“External Sites”).  We have no control over the privacy practices or the content of these External Sites, and we are not responsible for (and under no circumstances shall be liable for) the contents content or the privacy policies of those External Sites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

  1. Access to Personal Information

You may review, update, correct or delete certain personal information associated with your account by logging into your Account. If you wish to update or delete other personal information, you can contact us using the contact points specified below in Section 18.  To the extent authorized by law, we will take steps to modify or delete your personal information as soon as is practical, but some information may remain in archived/backup copies for our records or as otherwise required by law.

  1. Contact Information

If you have any questions regarding this Privacy Policy or exercise your information rights, please contact us using the contact information provided below:

Hyde Park West Telecommunications, LLC

6929 North Hayden Road

C4-160

Phone: 4806301263

Email: [privacy@hoo-nah.com]