Your privacy is important to Powell Labs. We value the trust you place in us when you subscribe to Powell Labs branded cable video, Internet, phone, and/or home security services (collectively, the "Powell Labs Services"). We take seriously the responsibility of protecting your privacy and the information we collect about you.
We commit to:
You should read the privacy policies for these other products, services, websites, applications and devices to understand their privacy practices; those privacy policies will apply to those third parties' collection of your information, even if access to such content or use of such products or devices requires you to be a Powell Labs subscriber; for example, some of the premium streaming services available online that require you to authenticate your subscription using your Powell Labs username and password.
In order to provide you with our products and services and to keep you informed, we collect a variety of information about you when you interact with us or use our products, services, websites and applications. This information is needed for us to efficiently provide our services to you on a cost-effective basis and to tailor our products and services to best meet your needs and interests. For example, in order to provide timely and effective customer service, we keep track of when you called, what the issue was and what is the best way to get in contact with you.
If you are a Powell Labs customer and you allow others to access and/or use your accounts, products or services, we will collect information about those users, as well. We may also collect information about you from third parties.
We collect information you provide to us when you establish a customer and when you contact us or otherwise communicate with us, such as:
When you use the Powell Labs Services, we automatically collect information, such as:
If you subscribe to or use services that require us to transfer or store communications such as a Powell Labs email account or a Powell Labs voice product that includes a voicemail service, it will be necessary for us to collect the content of those communications to provide you with the service you have requested because it is required in order for the services to function. Additionally, we collect the content of any files you store in our cloud storage services and other information when it is necessary to provide you with the products or features of the services you use.
We also collect device information, including your IP address and information about your browser, operating system, and platform type. The collection of this information, including IP addresses and the referring websites, is required in order for us to provide Internet service and for users to communicate with each other and with websites on the Internet.
When you access our network, we may collect general location information, such as the city or zip code that correlates with the license of your device IP address, or more precise geolocation data that indicates where you are at a specific point in time.
When you first visit or use any Powell Labs mobile application that collects precise geolocation information to access a Powell Labs Service to which you subscribe, we will request permission to collect and use such information. You can prohibit the collection of this information through your device's settings (see "Your Choices") but it may limit certain functions and features of the application.
We may collect information from third parties for purposes related to delivering the Powell Labs Services to you. This includes information to verify information you have provided and from credit reporting agencies to determine your creditworthiness, credit score, and credit usage.
If you rent your residence, we may have a record of whether landlord permission was required prior to installing our cable facilities as well as your landlord's name and address.
We receive information from content providers and other platform providers when you use your Powell Labs account to authenticate your use of Powell Labs Services through that provider's platform or device. For example, a Powell Labs subscriber to HBO will have access to the HBOGO app on their mobile device. When using that app, the Powell Labs subscriber will be required to provide their Powell Labs user information to HBO, which then provides that information to Powell Labs to confirm that the HBOGO user is a subscriber.
We also obtain additional information from outside sources, such as research consultants and marketing firms. We may collect commercially available demographic information about you or your community available from third parties, such as age, gender, and preferred language. We may also collect commercially available interest data, such as whether you like to travel or are a sports enthusiast.
First and foremost, we use the information we collect to provide you with reliable, high quality products and services. We also use the information we collect to communicate with you, make improvements to our products and services, investigate theft and other illegal activities, and personalize your experience, as described below. This may involve linking and combining information about you from across the Powell Labs platform of products and services, as well as from third parties ("Combined Information").
We use the information we collect to:
We use the information we collect to deliver and personalize our communications with you. For example, if you use an interactive or transactional service, e.g., responding to a survey or ordering a pay-per-view event, we will use that information and information from your account to send you billing information, as well as recommendations for additional Powell Labs products or services that may be of interest to you and to provide you with a more personalized experience. We may use the information to remind you of a service appointment, to follow up with you after a service request, and to send you important service-related notices and announcements.
We may send you promotional communications for products and services that may be of interest to you through the mail, over our cable system, by phone or SMS, or online. Some of these communications may be directed to you because of the Powell Labs services to which you subscribe or your interactions on the Powell Labs platform, and some may be directed to you because of your general geographic location. For example, if we are launching a new service in limited areas, only residents of that particular area will receive that promotional communication. This is often called "zone" advertising.
We use the information we collect to create business and marketing reports (the "Reports") to provide insights into what products and services our customers are using, how long they are using our products and services, how some of our services are accessed, and what additional products and services may be of interest to our customers. In the video context, for example, these Reports contain information such as channel tuning, the time a channel is changed, when a Powell Labs set-top box is "on" or "off", whether a program or commercial was watched to its conclusion or skipped, and whether the content was accessed during its regular airing schedule, from our on-demand service, or through a Powell Labs website app, or a third party's platform. We may create similar reports in the phone, broadband, and home security contexts that measure and analyze service usage information, such as the peak times of usage, the amount of bandwidth used, and the amount - but not the content - of data stored on our systems.
We use some of the information we collect to make the marketing and advertising you see on the Powell Labs Platform more relevant to you, as well as to market the Powell Labs products and services on other websites and platforms. Many of our marketing and advertising activities use information that does not personally identify you, such as your ZIP Code, your IP address, advertiser IDs and other persistent identifiers that are not directly linked to any identifiable information. Some of our marketing and advertising activities, however, do include the use of information that personally identifies you. For example, we use your postal and email address to deliver marketing and advertising to you. We may also use Combined Information to create marketing and advertising campaigns. For information about how to limit the use of information for these purposes, see the "Your Choices" section below.
Some of the advertisements you see on cable channels are placed by us. Some of those advertisements are placed in particular shows or channels; others are shown in particular geographic areas. Some of our cable advertisements will ask for your permission to take certain actions, like mail you information or allow the advertiser to contact you. In some areas we will be able to address advertisements to your household through our cable system that will be more relevant to your interests based on your Video Usage Information and/or Combined Information. For information about how to limit the use of information for these purposes, see the "Your Choices" section below.
We may place "cookies" in your browser that contain information about you or your account when you set up a personalized service or customize your settings and preferences on our websites or mobile applications. Cookies enable us to help diagnose problems with our services, control the display of ads, track usage patterns, gather demographic information, analyze trends, conduct research, and otherwise administer the Powell Labs services. We do not store sensitive information such as your password, e-mail address or credit card number in cookies.
We use third party service providers to place advertisements for the Powell Labs services on the Internet. These providers use standard tracking technologies used by most major websites and mobile applications to collect non-personal information about your visits to our websites and mobile applications, as well as your interaction with our products and services. These providers may also use information about your visits to other sites to send interest-based advertisements for other products and services and to gauge the effectiveness of advertisements. We do not permit these third parties to collect or use information that personally identifies you, such as your name, address, phone number or email address.
We share information with others when it is necessary to provide you with Powell Labs Services to which you subscribe, and others in the limited circumstances described below. We do not sell or otherwise share information that personally identifies our customers, including their Internet Usage Information, Video Usage Information, or Call Detail Information, to third parties for those third parties' own use, such as marketing or advertising of their own products and services. While we have no plans to do so, if we ever changed this business practice, we would provide customers with advance notice and obtain their express consent.
We may disclose any information about a customer's account and use of a service or feature to the primary account owner after appropriate authentication. The primary account owner may also authorize other users to access information on the account, which may include information about the primary account owner's use of the relevant service.
We may share information about you with other Powell Labs related companies in order to provide the services to which you subscribe, or to make your Powell Labs experience more streamlined, such as through combining account information into a single location for easier access. We may also share information about you with these related companies for their own marketing purposes when we have any necessary consent required to do so.
We may disclose your information to third-party service providers who perform business activities and functions on our behalf to support our interactions with you such as billing and collections, payment processing, analytics and research, marketing, service delivery and customization, maintenance and operations, and fraud prevention. These third-party service providers are authorized to use your personal information only as necessary to provide these services on our behalf.
If you subscribe to any Powell Labs Services, we may be required by law to disclose information about you, including information that personally identifies you, your use of our services, and the content of your communications, to governmental entities upon receipt of valid legal process. These disclosures may be made with or without your consent and with or without notice, in compliance with the law, including the terms of process.
If you subscribe to Powell Labs cable video service and a governmental entity is seeking information about your selection of video programming, the Cable Act requires the governmental entity to obtain a court order. In the proceeding relevant to the issuance of the court order, the government must provide clear and convincing evidence that you are reasonably suspected of engaging in criminal activity and that the video records sought would be material evidence in the prosecution of the case. You are to be afforded the opportunity to appear and contest the governmental entity's claims in such proceeding.
We may also disclose personally identifiable information about you, without your consent, to protect our Customers, employees, or property; in emergency situations; to enforce our rights in court or elsewhere, or directly with you, for violations of service terms, conditions or policies; and/or as otherwise required by law.
We do not sell or share information that personally identifies our customers with third parties for their own marketing or advertising purposes.
If you subscribe to our telephone service, your name, address and/or telephone number may be transmitted via Caller ID, published and distributed in affiliated or unaffiliated telephone directories, and available through affiliated or unaffiliated directory assistance operators. We take reasonable precautions to ensure that non-published and non-listed numbers are not included in the telephone directories or directory assistance services, although we cannot guarantee that errors will never occur. Please note that Caller ID blocking may not prevent the display of your name and/or telephone number when you dial certain business numbers, 911, 900 numbers or toll-free 800, 855, 844, 866, 877 or 888 numbers. But note that Powell Labs Mobile does not publish directories of customers' wireless phone numbers and we do not make those numbers available to others for listing in directories.
Some of the advertisements we display may invite interactive or transactional follow-up from you. When you interact and provide your consent, we may share your contact information with such advertiser for the purpose of fulfilling your request. We may also share individually de-identified and/or aggregate information, including our business and marketing reports, with third parties for their own purposes.
If we enter into a merger, acquisition, or sale of all or a portion of our assets, we may transfer information about you, including information that personally identifies you, as part of the transaction.
You have many choices in controlling how we use and share your information for marketing and advertising purposes. For instance, you can always choose whether to receive promotional emails or text messages. You may email Hello@PowellLabs.com to manage your privacy preferences, including:
Some of the preferences will only apply when you subscribe to Powell Labs services and may require additional account information. If you make changes to your contact information or get a new account, you will need to review and update your privacy preferences.
If you do not have access to Internet service, you may call us at the number provided on your monthly bill statement to be added to any of these lists.
Please note that even if you choose to limit the use of information or communications for marketing and advertising purposes, you will still receive general advertising and zone advertising, in addition to service-related messages.
When you first visit or use a Powell Labs application on your mobile device, we will request permission to collect and use your device's precise geolocation. You can choose not to permit the collection of this information, but it may limit certain functions or features of an application. You can manage the collection of your location information through your device's settings.
When you initiate an interaction with one of our representatives, such as a phone call or a chat, we may ask for your oral consent to our use of your CPNI for the purpose of providing you with an offer for other products or services, such as the Powell Labs cable video service. If you consent, we may use your CPNI for the duration of such interaction to offer you those additional products and services.
If you subscribe to the Powell Labs Voice(r) or Powell Labs Mobile service, we would like to use the CPNI information we have on file to provide you with information about products and services or special promotions for other communications-related products and services to which you do not already subscribe. You have the right to restrict this use of CPNI. If you deny or restrict your approval for us to use your CPNI, you will experience no effect, now or in the future, on how we provide any services to which you subscribe.
We will wait at least thirty days from the date we first provide notice to you, as a subscriber of the Powell Labs Voice(r) service, before we use your CPNI for this purpose. During that time and at any time after, you may opt-out of our use of your CPNI for these marketing purposes by calling us at the number provided on your monthly billing statement.
We take our responsibility to secure the information we collect and maintain seriously. We use reasonable security, including technical, physical and administrative controls, to secure the information we collect and maintain. However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose Powell Labs information.
You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorized interception of your personal information. You are responsible for the security of your information that you transmit to us or view, download, or otherwise access when using unencrypted, public or otherwise unsecured networks. For more information on things you can do to help protect the privacy of your own information, visit -www.OnGuardOnline.gov.
Section 631 of the federal Cable Act gives a subscriber to the Powell Labs Cable Act Services the right to know about the personally identifiable information we collect and how we use it; under what conditions and circumstances and the types of persons and entities to whom we may disclose personally identifiable information; how long we maintain personally identifiable information; the limitation on our ability to collect and disclose personally identifiable information collected from the cable system; and a subscriber's rights under the Cable Act concerning personally identifiable information and its collection and disclosure.
Personally identifiable information is information that identifies a particular person; it does not include de-identified or aggregate data that does not identify a particular person or persons.
The Cable Act permits us to use the cable system(s) to collect personally identifiable information about our subscribers when it is necessary to render the Powell Labs Cable Act Services or other services we provide and to detect unauthorized reception or use of the Powell Labs Cable Act Services. We may use the cable system to collect personally identifiable information about a subscriber for additional purposes with a subscriber's prior written or electronic consent.
If you subscribe to a Powell Labs service that is governed by the Cable Act, we will maintain information that personally identifies you and that is associated with your use of such service for as long as necessary for the purpose for which the information was collected, which may be as long as the duration of your subscription and after you have terminated your subscription, in some instances. For example, we may keep information that personally identifies you as necessary to comply with laws governing our business, such as tax and accounting requirements that require record retention, to satisfy pending requests for access by a subscriber to his/her information or pursuant to a court order, or to respond to your inquiries or otherwise communicate with you after you have terminated your subscription. We will destroy or de-identify such information when it is no longer needed for such purposes.
If you believe that you have been aggrieved by any act of ours in violation of law, we encourage you to contact us in order to resolve your question or concern. You may also enforce the limitations imposed on us by the Cable Act with respect to your personally identifiable information through a civil lawsuit in federal district court seeking damages, attorneys' fees, and litigation costs. Other rights and remedies may be available to you under federal or other applicable laws as well. Your Powell Labs Residential Services Agreement contains your agreement that, to the extent permitted by law, any claims under the Cable Act may be enforced in arbitration.
Section 222 of the Communications Act provides additional privacy protections for information about the quantity, technical configuration, type, destination, location, and amount of your use of the Powell Labs telecommunications services, and information about your Powell Labs phone service that is contained on your bill. This information, when linked to an identifiable customer of such service, is known as customer proprietary network information or "CPNI." CPNI does not include a customer's name, address, and telephone number, which is defined by the Communications Act as "subscriber list information" and is not subject to the CPNI protections. However, that information is considered "personally identifiable information," and is subject to the Cable Act protections described above.
We strive to keep our records accurate. If any of your information changes, please notify us immediately so we can update our records.
If you subscribe to a service subject to the federal Cable Act's requirements and you would like to see the personally identifiable information we maintain in our business records, please send a written request to your local office or call us at the number provided on your monthly billing statement and we will make an appointment for you to visit during normal business hours. You will only be permitted to examine records that contain personally identifiable information about your account and no other account. If your review reveals an error in our records, we will correct it. We reserve the right to charge you for the cost of retrieving and photocopying any documents that you request. You may also be able to access certain information about you or your account by contacting one of our customer service representatives at [insert], or by logging in to your online account.
If you make a written request for a copy of your CPNI, we will disclose the relevant information we have to you at the address we have for your account, or to any person authorized by you, if we reasonably believe the request is valid. For telephone and online access to your CPNI such as outbound call detail records, we require that you first authenticate your identity using a password established using our online system. We generally do not provide our customers with records of calls received, records that are only in our archives, other records that we do not furnish as part of a telephone bill, web-browsing history, IP address logs or any other information that we do not create or maintain in the ordinary course of business unless there is a court order or similar legal process. If there are errors in names, addresses, or telephone numbers in our vendors' directory lists, or if you have been omitted from the directory, the correction cannot be made until the next available publication. Please understand that we may have no control over information appearing in directory lists or provided by directory assistance services which we do not own.
Questions about Powell Labs's privacy protections and practices should be sent to:
Powell Labs Inc
Attn: Privacy and Cybersecurity Counselor
103 East Ave
Fremont, MI 49412
You may also contact your local customer service office. You can find the phone number for your local customer service office on your monthly bill statement or by visiting our website at www.powelllabs.com.
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