Telnet USA Privacy Policy

Last Updated: 6/14/2023

Changes from previous version: Simplified to reflect that the Company’s size and operations in various states does not bring Telnet USA under the requirements of various state privacy laws. Telnet USA will need to monitor its operations in all jurisdictions in order to determine whether those laws may apply to Telnet USA’s operations.

Contents

• Introduction and Overview
• Definitions
• The Personal Information We Collect
• How We Use Personal Information We Collect About You
• How We Share or Allow Access to Your Personal Information
• How You Might Share Your Information with Third Parties
• Your Rights and Our Obligations Related to Your Customer Proprietary Network Information
• Your Advertising Choices and Consent Options
• How We Store, Retain, and Protect Personal Information We Collect About You, and How Long We Keep Your Personal Information
• Governing Law and Notice to Non-U.S. Residents
• Information from Children
• Nevada Privacy Rights
• Telnet USA and Various State Privacy Laws
• Changes and Updates to this Privacy Policy
• Correcting and Updating Your Information
• Contact Us

1. Introduction and Overview

Telnet USA, LLC (“Telnet USA” “we”, “our”, or “us”) is committed to protecting your privacy. This Privacy Policy is provided to help you better understand the kinds of information Telnet USA collects from and about you when you visit our Website (“Site”), use our mobile applications (each an “App”) and use our online services, devices, products, or services (collectively referred to as the “Services”).

This Privacy Policy applies to you and anyone who a) applies for Telnet USA Wireless Services or government benefits available for eligible applicants in conjunction with our Services; and/or b) uses our Services under your account, except where we identify for you that separate terms and conditions apply.

Please take a moment to review the full terms of our Privacy Policy below, because by accessing and using the Site containing a link to this Privacy Policy, or by using our Services where a link to this Privacy Policy is provided, you agree to the terms and conditions of this Privacy Policy and any updates we make to it. If you do not agree to the terms and conditions of this Privacy Policy, then please do not provide us with your information. Please note, however, that if you choose to limit the information that you provide to us while using the Site, you may not be able to use or participate in certain features of the Site.

This Privacy Policy is part of the Terms and Conditions and Agreement to Arbitrate Disputes and Judge or Jury Trial Waiver (“Terms and Conditions”) governing the use of our Services, available at https://usatelnet.com/terms-and-conditions/. To the extent that any provision or clause in our Terms and Conditions conflicts with any provision or clause in this Privacy Policy or a specific service plan we offer, the terms of those more specific documents will govern.

2. Definitions

“Call Detail Information” means any information that pertains to the transmission of specific telephone calls, including, for outbound calls, the number called, and the time, location, or duration of any call and, for inbound calls, the number from which the call was placed, and the time, location, or duration of any call.

“Device” means any phone, smartphone, tablet, accessory, or other device provided or sold to you by Telnet USA or that you activate or use with our Services.

“Geolocation Data” means any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area.

“Precise Geolocation” means any data that is derived from a device and that is used or intended to be used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed by law or regulation.

“Personal Information” is information that identifies you or is reasonably capable of being associated with or linked, directly or indirectly, with you or your household. It does not include aggregate, de-identified, and/or anonymous information that is not reasonably capable of being associated with or linked, directly or indirectly, with you or your household.

“Services” means voice telephony (“talk”), text messaging (“text”), broadband Internet access services (“data”), and any other services provided to you by TelnetUSA, services and devices subject to Affordable Connectivity Program discounts, and prepaid wireless service.

“Underlying Carrier” means the wireless provider whose facilities we use to provide you wireless Services.

3. The Personal Information We Collect

We may obtain Personal Information about you in 3 ways: 1) personal information you provide; personal information automatically collected from you; and 3) personal information we receive from third parties

3.1. Personal Information You Provide Directly to Us.

Telnet USA collects information from you when you choose to share it with us. This may include when you use our Services, register or create an online account with or through our Services, request information from us, sign up for newsletters or our email list, rate or review our products and services, request customer support, or otherwise communicate with or contact us. The information we collect may include your name, address, email address, telephone or mobile number, date of birth, last four digits of your social security number, photograph, and user name.

You also may provide us with certain information in connection with the following transactions:

Financial Transaction Information: such as such as credit card, debit card, checking account information, purchase and order history, and billing information related to your use of our voice and text services; documentation of participation in an eligible government low-income or financial assistance program, documentation demonstrating proof of income, or your Social Security number, each of which will only be used to determine Affordable Connectivity Program (“ACP”) eligibility.

Survey Information: From time to time Telnet USA may conduct surveys of our customers and/or users of our Services or Apps. Surveys are completely voluntary to those using our Services. The surveys may require you to provide identifiable information in exchange for the information or services provided by the surveys. We may use this information in a non-identifiable way.

3.2. Personal Information Automatically Collected from You.

Whenever you visit or interact with the Services, we along with any third-party advertisers and/or service providers, may use a variety of technologies to automatically or passively collect certain information about your activities through the Services.

Computer or Device Information: We may automatically collect your Internet Protocol (“IP”) address or other unique identifier or information from the computer, mobile device, tablet or other device you use to access the Services, including but not limited to your browser type, device type, device identification number, media access control (“MAC”) address, operating system, software version, phone model, phone operating system, carrier information, and the domain name from which you accessed the Services.

Usage Information: We may collect information about your use of the Services, including the date and time you visit the Services, the areas or pages of the Services that you visit, the amount of time you spend viewing or using the Services, the number of times you return to the Services, other click-stream or usage data of our Services, emails that you open, forward, or click-through to our Services, and other websites that you may visit. This also may include the Customer Proprietary Network Information (“CPNI”) as described in the CPNI section below.

Use of Third Party Analytic Technologies: We may use third parties’ analytics and tracking tools to better understand who is using the Site or App, how people are using the Site or App, how to improve the effectiveness of the Services and related content, and to help us or those third parties serve more targeted advertising to you across the Internet. These tools may use technology such as cookies, web beacons, pixel tags, log files, HTML5 cookies, or other technologies to automatically collect and store certain information. They may also combine information they collect from your interaction with the Site or App with information they collect from other sources. We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.

Location Information: Telnet USA collects information about your location based on your proximity to cell towers. We disclose this information as necessary to respond to 911 or other emergency-related situations as provided by law.

3.3. Personal Information We Receive from Third Parties

We may collect any category of Personal Information from affiliates, business partners, federal and state regulators, subsidy program administrators, compliance and service support entities, or third parties (such as social media platforms, data aggregators, public databases, and other commercially available sources), which may include the information you provide those entities or that they automatically collect from you.

Please note that the information we may receive from those third-party sites (such as Facebook, Instagram, Twitter and YouTube) is governed by the privacy settings, policies and/or procedures of the applicable platform, and we strongly encourage you to review them before submitting any information using a social media platform.

We may combine the various types of Personal Information we receive from or about you, including information you provide to us, information we automatically collect, and information from other sources, and use it as described in this Privacy Policy.

4. How We Use Personal Information We Collect About You

We may use your Personal Information for a variety of business and commercial purposes, including for:

Verifying Eligibility and Subscribing You to Our Services. To verify your identity and eligibility for the ACP and subscribe you to our Services, including to execute requests to port your phone number.

Managing Billing and Payments. To complete your purchases and transactions, including billing and payment processing.

Providing, Improving, and Maintaining Our Services. To provide, improve, and maintain our Services, including to: initiate and render our Services; maintain the accuracy of the information we collect; track, measure, and analyze the usage and operations of our Services; maintain, manage, optimize, and resolve problems with our wireless networks, information technology, and our Services; develop and improve our business, content, products, and Services; and interact with third-party services, at your request.

Providing Customer Service. To respond to questions and comments about your account and Services, to communicate with you about your account status and technical issues, and for training or quality assurance purposes.

Preventing and Detecting Unlawful and Unauthorized Use. To prevent and detect fraud, abuse, and other unlawful and unauthorized use of our Services, including to investigate possible violations of our Terms and Conditions and any other contracts, and to otherwise protect the security or integrity of the Services, our business and property, and our rights and interests, and those of you, our other customers, our service providers or contractors, and other businesses.

Complying with Legal and Regulatory Obligations. To comply with our legal and regulatory obligations, including responding to legal process, such as subpoenas, court orders, and search warrants.

Emergency Situations. To allow responses to 911 requests and for other emergencies or exigencies in cases involving danger of death or serious physical injury to you or any other person.

Marketing and Advertising. To serve you promotional offers, content, advertisements, and other marketing about our Services, or those of our affiliates, partners, and third parties, through our website, applications, social media, direct mail, email, or manual, autodialed, or prerecorded calls and texts, each with your consent, where necessary, including by: personalizing marketing and advertising to your interests (“interest-based advertising”); measuring, analyzing, and optimizing the effectiveness of our marketing and advertising; and using your comments and communications with us about our Services as customer testimonials (with only your first name and your last name initial) or for other purposes that benefit us.

Conducting Surveys. To administer surveys.

We may use your Personal Information as otherwise disclosed and explained to you at the point of collection and with your consent, where necessary.

We may use your Personal Information as otherwise disclosed and explained to you at the point of collection and with your consent, where necessary.

5. How We Share or Allow Access to Your Personal Information

Except as provided in this Privacy Policy, we will not disclose, sell, or rent any of your information to any third parties without your consent. We may share your personal information in the following circumstances:

 To Our Affiliates. With our parent, subsidiary, and affiliate companies for business,operational, and legal purposes.

 To Our Service Providers or Contractors to Assist with Our Services. We use service providers or contractors who may need access to your Personal Information in order to provide services for us. These may include administering activities on our behalf, including network operations, website hosting, database management, information technology, billing and payment processing, customer service, analysis of our Services, and the sale and delivery of our Services. Billing and Processing may include the use or sharing of Call Detail Information. Call Detail Information may include Geolocation Data (and Precise Geolocation), such as your location when using our network. We do not authorize service providers or contractors to use or disclose the Personal Information they collect, except as necessary to perform services on our behalf, and require them to protect the confidentiality and security of the Personal Information they receive consistent with this Privacy Policy.

 For Identity Verification and Fraud Prevention Services. To help protect customers and consumers from fraudulent use of our Services, we share Personal Information or risk scores derived from such data with banks or other entities that provide us with fraud prevention services.

For Legal Process and Protection. We may disclose Personal Information to governmental authorities or other entities if we believe disclosure is necessary or appropriate, including:

to protect against fraudulent, malicious, abusive, unauthorized, or unlawful use of our Services;

to protect our network, databases, Services, Devices, users, and employees from physical or financial harm;

to investigate violations of our Terms and Conditions or other contracts;

to respond to subpoenas, court orders, search warrants, or other legal process;

to respond to requests for cooperation from law enforcement or other government entities, including pursuant to the Communications Assistance for Law Enforcement Act (CALEA), which may require that we monitor or facilitate monitoring and otherwise disclose the nature and content of communications transmitted through the Services or Devices without any further notice or liability;

to recover payment for previously-billed Services;

to facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to local, state, or federal governments and governmental agencies; and

in emergency situations involving danger of death or serious physical injury to you or any other person, to respond to 911 requests, and for other emergencies or exigencies.

In a business transfer or transaction. We may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Services in a manner that is consistent with this Privacy Policy.

For Commercial Marketing Purposes. With our affiliates, service providers, contractors, or marketing partners for our marketing and advertising purposes, including when we use our marketing partner’s analytic and advertising tools, such as cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies), HTML5 cookies, or other technologies that automatically or passively collect Personal Information from your use of our Services.

6. How You Might Share Your Personal Information with Third Parties

When using our Services, you may choose to install, access, or use services offered by third parties, such as websites and applications. Please also refer to the Acceptable Use Policy inside our Terms and Conditions, available at https://usatelnet.com/terms-and-conditions/. In some cases, our Services may have links to websites operated by third parties, plugins for social media services, or third-party advertisements.

When you interact with third-party services, you may be consenting to those third parties accessing, collecting, using, or disclosing your Personal Information through our Services or directing us to share or allow access to your Personal Information by those third parties, such as your IP address, browsing activity, or location information. Those services operate independently of our Services, and your Personal Information will be governed by their terms and conditions, including their privacy policies, not this Privacy Policy. We encourage you to review the privacy policies of any third-party services that you use to better understand their privacy practices. You may be able to restrict or disable the use and disclosure of certain information, such as your location information, using settings available on your Device or through the third-party services.

7. Your Rights and Our Obligations Related to Your Customer Proprietary Network Information

Customer Proprietary Network Information (CPNI) is information made available to us solely by virtue of our relationship with you that relates to the type, quantity, destination, technical configuration, geolocation data, and amount of use of the telecommunications services you purchase from us, as well as information related to the billing for those services.

CPNI does not include subscriber list information such as name, postal address, or telephone number. Under federal law, you have the right, and we have the duty, to protect the confidentiality of your CPNI. When we share your CPNI with our service providers or contractors, we require them to take reasonable measures to protect the confidentiality of that information.

We are permitted to use or disclose your CPNI for certain purposes without further notice or consent from you, including: to provide you with our Services; to market service offerings to you related to the services you purchase; to protect us, you, other subscribers, and other carriers from fraud, abuse, or unlawful use of the Services; and in an aggregate form. We also may use your CPNI, or share it with affiliates and third-party agents, for the purpose of offering you communications-related products and services, packages, discounts, and promotions that may be different from the types of services you have already purchased.

You have the right to opt out of use of your CPNI for marketing purposes and can submit an opt-out request by contacting us at cs@usatelnet.com, or call Telnet USA Customer Service at (888)-596-2553. Opting out will not affect our provision of Services to you or our use of your CPNI for permitted purposes. If you choose to opt-out, your choice is valid until you choose to opt in. You may also contact us to correct your CPNI or request that we disclose your CPNI to you.

We will not disclose your CPNI except when provided with your password, and we may implement other authentication measures. If you do not provide a password, we may not release your CPNI to you except by sending it to your address of record or by calling you at your telephone number of record. Be sure to use a strong password with our Services and not one you use for other services. We may disclose your CPNI to any “authorized user” that you have designated to us in writing or to any person who is able to provide us with your password.

8. Your Advertising Choices and Consent Options

Google Analytics and Google AdWords. We use Google Analytics on our Sites to help us analyze traffic and improve services. For more information on Google Analytics’ processing o 9 Personal Information, please see http://www.google.com/policies/privacy/partners/. You may opt-out of the use of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Our Sites also use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to our Sites. Any data we collect will be used in accordance with this Privacy Policy, and Google is responsible to abide by its own privacy policy. You can set your preferences for how Google advertises to you using
the Google Ad Preferences page: https://adssettings.google.com.

You have certain choices and consent options related to the use and disclosure of your Personal Information for advertising purposes. Exercising these choices and options will not affect our provision of Services to you. Please note that these choices and options may not prevent you from receiving all advertising; you may continue to receive generic advertising from us or interest-based advertising from third parties, depending on how they operate.

Interest-Based Advertising. You have choices and options concerning interest based advertising on our Services or across other websites and online services as follows:

To opt-out of collection and use of your Personal Information for interest-based advertising by companies participating in the Digital Advertising Alliance (“DAA”), please visit optout.aboutads.info or click on the DAA icon when you see it on an online ad.

To opt-out from the use of Personal Information about your online activities for interest-based advertising by Network Advertising Initiative (“NAI”) member companies, please visit optout.networkadvertising.org.

To opt-out of the use of your mobile device ID for targeted advertising, please visit www.aboutads.info/appchoices.

To prevent your Personal Information from being used by Google Analytics to measure and improve marketing and advertising and understand the use of our Services, including through Google AdWords, Google Display Network Impression Reporting, DoubleClick Platform Integrations, and Google Analytics Demographics and Interest Reporting, add the Google Analytics opt-out plugin to your browser, available at tools.google.com/dlpage/gaoptout.

To manage flash cookies, visit Adobe’s Global Privacy Settings Panel .

You may be able to adjust your browser, computer, or device settings to disable cookies, remove or prevent the storage of HTML5, or control other advertising and analytics technology to stop or reduce the amount of interest-based advertising you receive, but doing so may prevent you from using certain features of our Services.

Marketing Communications.  In accordance with our Terms and Conditions, you provide consent for us to contact you via email, voice call or text, including manual, autodialed, and prerecorded calls and texts.  You also provide consent for us to use CPNI for marketing 10 purposes, as described in the Terms and Conditions.  You may limit or revoke these authorizations as follows:

Call us at 888-575-9192.

Unsubscribe from our email communications following the unsubscribe instructions contained within our emails.

Reply “STOP” to our text messages.

Your instructions to opt-out from these communications will be processed as soon as reasonably practicable. Please note that exercising a marketing opt-out will not affect the services you receive and will not affect Telnet USA’s right to contact you about the services to which you subscribe, including notifications regarding compliance obligations related to those services (e.g., non-usage, de-enrollment, and collection notices).

Do Not Track. Because Do Not Track (“DNT”) and similar signals do not yet operate according to common, industry-accepted standards, our Services may not respond to DNT signals.

9. How We Store, Retain, and Protect Personal Information We Collect About You, and How Long We Keep Your Personal Information

TelnetUSA has implemented reasonable technology and security features, to safeguard the privacy of your Personal Information from unauthorized access or improper use and will continue to enhance our security measure  as technology becomes available. Unfortunately, there is no such thing as foolproof security on the Internet, and therefore, TelnetUSA makes no guarantees with regard to the sufficiency of our security measures.

We will keep your Personal Information as long as necessary to provide your Services, or as otherwise required by federal or state law, subpoena, or court order. FCC regulations require us to keep:

ACP records for as long as an ACP participant receives a discount but no less than six (6) years.

911 call data for two (2) years.

The Personal Information we collect from or about you is stored on servers which we take commercially reasonable efforts to secure in the United States, subject to the laws of the United States. Electronic access to the databases and physical access to the servers on which this Personal Information is stored are restricted to those employees, agents, contractors, service providers, and other third parties who have a business need for such access. They will only access and use your Personal Information based on our instructions and they are required to keep your Personal Information confidential. While we take reasonable steps to help ensure the integrity and security of our network and servers, we cannot guarantee their security, nor can we guarantee that your communications and information will not be intercepted while being transmitted over our underlying carrier’s network or the Internet.

Your Personal Information is stored on servers in the United States; however, some of our service providers may store information on servers hosted in other countries. As such, your Personal Information may be subject to the laws of other countries, where the data protection and other laws may differ from those of the United States. Should your Personal Information be transferred to other countries, we will require our service providers to protect your Personal Information. Your Personal Information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.

TelnetUSA may assign you a user ID and a password when you as part of your participation and access to the Site and your account. Only you may use your user ID and password. You may not share your user ID and password with anyone else, and you are solely responsible for maintaining and protecting the confidentiality of your user ID and password. You are fully responsible for all activities that occur under your user ID. You play a role in protecting your information as well.

10. Governing Law and Notice to Non-U.S. Residents

Our Services are solely intended for individuals located within the United States (“U.S.”) and its territories and are subject to U.S. law. If you are located outside of the United States and its territories, please do not use the Services.

If you do not reside in the United States and provide Personal Information to us, please note that your Personal Information will be transferred, processed, collected, used, accessed and/or stored in the United States and subject to U.S. laws. The laws in the United States may not provide the same protections for your Personal Information as the jurisdiction in which you are located. Do not provide your Personal Information to us if you do not want this information to be transferred or processed outside of your country, or if the laws in your country restrict such transfers.

11. Information from Children

Our Services are not directed toward children, and we do not knowingly collect Personal Information from children under the age of 13.

If you are a minor, please do not provide us with any Personal Information or use or access the Services without receiving your parent’s or guardian’s permission. If we learn that we have collected any Personal Information from a child under the age of 13, we will take steps to delete the information as soon as possible. If you believe that we might have any Personal Information provided from a child under 13, or if you are a parent or guardian of a child under 13 that has provided us with Personal Information without your consent, please contact us using the information below to request deletion of the child’s information.

For clarification, you (as a customer) may provide us information about children within your family, such as school enrollment or school breakfast/lunch documentation, to qualify for the ACP. That information may be collected and stored by our service providers, and provided to the Universal Service Administrative Company (USAC).

12. Nevada Privacy Rights

Nevada law allows consumers to opt-out of the sale of personally identifiable information by online service providers such as website operators. Telnet USA does not sell personally identifiable information and does not intend to do so.

13. Telnet USA and Various State Privacy Laws

Telnet USA is not subject to the defined scope of many state privacy laws, such as the California Consumer Privacy Act and the California Privacy Rights Act (together, “CCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (CPA), and the Connecticut Data Privacy Act, and therefore the specific rights and obligations identified in these laws do not currently apply to Telnet USA.

However, California, Virginia, Colorado, and Connecticut residents may refer to these Privacy Policy provisions regarding our current data practices and may contact us regarding data inquiries or further information requests via the Contact Us section below.  We also recognize that privacy laws continue to evolve rapidly, so we are undertaking reasonable means to monitor developments in these laws and update our polices accordingly.

14. Changes and Updates to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. When we do, we will post the changes on this page. We will give you notice of any materially adverse changes to this privacy policy and may give you notice of all other changes but reserve the right to make such modifications immediately if required. It is your responsibility to regularly check this page to determine if there have been changes to the Privacy Policy and to review such changes.

The most current version of this Privacy Policy can be viewed by visiting our website and clicking on “Privacy Policy” located at the bottom of the pages. Any changes will take effect immediately. The effective date of this Privacy Policy is stated below. Continued access or use of our Services following the effective date of any changes shall indicate your acceptance of such changes. If you do not agree to the modified provisions of this Privacy Policy, you must discontinue your access and use of the Services.

15. Correcting & Updating Your Information

Please help us keep your data accurate by informing us of any personal information change promptly. To update your information or discontinue the Services, please use one of the methods in our Contact Us section below.

16. Contact Us

If you have any questions or concerns about this Privacy Policy or how we treat your Personal Information, please contact us using the following information: info@usatelnet.com or cs@usatelnet.com.