SureStream Privacy Policy

SureStream (“we,” “our,” or “us”) cares about and is committed to protecting the privacy of our Customers’ and Website Users’ personal information. SureStream has drafted this privacy policy (this “Privacy Policy”) to explain how we collect, maintain, use, disclose and protect personal information. This Privacy Policy also details the various rights and choices you may have when it comes to your personal information.

WHEN THIS PRIVACY POLICY APPLIES. This Privacy Policy applies to the information we collect when you use or access SureStream-branded Services, including our residential and business services, Internet services and voice services (such as SureStream Phone and SureStream Mobile). This Privacy Policy also covers our privacy practices with respect to visitors to our website located at www.SureStreamInternet.com (the “Website”). It also applies to the information we collect about you from third parties. Because this Privacy Policy describes the privacy practices for all of our SureStream Services, some parts may not apply to you.

1. DEFINITIONS. This is what we mean when we use the following terms in this Privacy Policy:
  - “SureStream” refers to SureStream, LLC, and its parents, subsidiaries and affiliates.
  - Services” means the SureStream-branded residential and business services provided, including Internet services, voice over Internet protocol (“VoIP”) phone services, our related products and platforms, our support services, and our Apps.
  - “Apps” means the applications available for use by SureStream Customers,.
  - “Customer” means a customer of any SureStream Service.
  - “User” means a visitor to a Website.
  - “Information” means the information we collect about you and your use of the Services or Websites. It includes information you provide to us, information we collect when you use the Services or Websites, and information provided to us by third parties. Depending on how it is used or disclosed, some Information can be Personal Information or De-identified Information, as those terms are defined below.
  - “Personal Information” Personal Information means information that directly identifies or can reasonably be used to identify a particular individual (for example, email address). Personal Information does not include publicly available information, aggregate data or De-identified Information.
  - “De-identified Information” or “Anonymous Information” is information that does not directly identify and cannot be reasonably linked to a particular individual. We treat IP addresses and other unique identifiers – such as cookie IDs, advertising IDs, device IDs and household IDs – as De-identified Information when they cannot reasonably be used to identify a particular individual.
  - “Device Identifiable Information” or “DII” is a type of De-identified Information that directly identifies or can reasonably be used to identify a specific browser, device, or group of devices, but doesn’t directly identify and cannot reasonably be used to identify a specific individual.
  - “Financial Information” means information related to your financial relationship with us, including your credit card or banking information, your Social Security Number, payment history, and credit history.
  - “First Party Advertising” is advertising or marketing communications for our products and services.
  - “Service Providers” means third party vendor(s) that perform services on our behalf in connection with the offering, operation and provision of the Services or other legitimate business activities, for example, fraud prevention, payment processing, billing, shipping, e-commerce, analytics, and marketing services.
  - “Targeted Advertising” is advertising delivered to specific audiences or consumers based on attributes such as viewing behavior, websites visited, demographic data, interests, geolocation and/or inferences or predictions regarding likely interest in the advertisement. Targeted Advertising can be either First Party Advertising or Third Party Advertising.
  - “Third Party Advertising” is advertising or marketing communications for a third party (including, for example, for non-SureStream products and services).
2. Information We Collect and How We Collect It. When you visit one of our Websites or subscribe to and use our Services (including our Apps), SureStream collects certain types of information about you, as described and illustrated below. We may collect this information directly from you when you provide it to us, automatically when you use a Service, from third parties, or on one of our Websites.
  - Information You Provide To Us. When you sign up for service, purchase a product or service, create an account, call, text or email us, use online account tools (for instance, when you chat online with an agent or log into your account on a Website, complete customer surveys, fill out a form on a Website, or otherwise communicate with us, we collect the Information you provide to us, which may include Personal Information, such as:
    - - your name and contact information, such as, service address, billing address, work address, email address, phone numbers;
      - credit card number, bank account number or other Financial Information (including payment card information, banking information);
      - government identification, including personal identifiers, such as date of birth, social security number or driver’s license number;
      - passwords and other information you provide to authenticate your access to the Services;
      - records of correspondence and other communications, including recordings of calls or online chats with our customer service, technical support or sales agents; and
      - preferences on your account or respond to customer satisfaction or other surveys.
    We may also access and use Information you provided to us previously in connection with the provision of other services. For example, if you are an existing Internet customer and then sign up for another SureStream service, we may access and use your Information to supplement the information we collect from you in connection with the new service.
  - Information We Collect When You Use the Services. As part of our normal course of business, we generate and collect Information about your account and use of the Services in order to provide our Services, to detect unauthorized reception of our Services, and for other purposes described in Section 3 below. The Information we collect may include:
    - Billing and Account Information. We collect and generate Information such as account number, billing and payment history, types of Services to which you subscribe or products you purchase, email addresses we assign to you, your maintenance and repair history, and the kind, location, configuration, and device identifiers, MAC and IP addresses of equipment (including TV sets, set-top boxes, CableCARDs, modems, tablets, smart speakers, and other IP enabled devices) connected to our facilities.
    - Internet Services. If you are an Internet customer, we may automatically collect and associate with your account certain information concerning your use of our Internet service, such as the IP address(es) assigned, MAC addresses of equipment that is used, bandwidth used, system and connection performance, browsers used, dates and times of access, and Internet resource requests. We also collect usage statistics and network traffic data and geolocation information.
    - Location Information. We may collect Information from the devices you use to access the Services that tells us where you are at a given point in time. For example, we may know that you are at home when you chat with an online agent on a Website.
    - App Information. When you use our Apps, we may collect application usage information, as well as records of the kind, location, configuration, device identifiers, MAC, and IP addresses of equipment utilized in association with the Apps. We may also collect App-specific information.
  - Information Provided by Other Sources. Sometimes, we may obtain additional Information from publicly available sources such as research consultants, data service providers, credit reporting agencies, and marketing firms to supplement the Information we collect from you. We may combine this Information with Information that we collect from you. We may also obtain Information from our business partners and/or their service providers or clients to assist with data collection, reporting and ad response measurement, as well as to assist with delivering and analyzing the performance of relevant marketing messages and advertisements. The types of Information that we may receive from third parties includes, but is not limited to demographic data (including, but not limited to gender or age range) and interest data (including, but not limited to demonstrated interest in or interaction with a particular product/website). The demographic data we receive can include information regarding ethnicity and religious beliefs. We may also obtain credit information about you from outside credit reporting agencies to help us with customer authentication, fraud prevention and creditrelated decisions.
  - Information Automatically Collected on Websites: When a User visits one of our Websites we may collect their Information in the following ways:
    - Cookies. We and our Service Providers use “cookies” to collect information about your visit to our Website and to manage information concerning your preferences. A cookie is a small encrypted computer code added to a file on your computer as a record of your visit. It does not collect or provide your name or any other personal information about you. It can, however, be used by the Website to note information about your visit, such as your type of web browser, operating system and IP address, to better tailor the Website for you. It can also be used to recognize you when you return as a repeat visitor. You can control what cookies are accepted by your computer through the settings on your web browser or by deleting them from your computer. Doing so, however, may limit the personalization available to you.
    - Clear GIFs. We and/or our Service Providers may use clear GIFs (also known as “web beacons,” “Internet tags,” or “pixel tags”). These are lines of code that allow websites to summarize overall visitor usage patterns and to provide personalized services. We may use clear GIFs to track visitor preferences or to gather aggregated information about visitor usage patterns. We do not use clear GIFs to collect Users’ Personal Information.
    - Passive Automatic Electronic Collection. We and/or our service providers collect and log information automatically when a User visits one of our Websites. For example, we collect your IP address, the name and location of your Internet service provider, the type and version of your browser, the length of time you visit the Website, your search queries on the Website, and the average number of pages you viewed. We use this log information for systems administration purposes and for technical troubleshooting. We may also use it to gather general demographic information about you, such as your general location.
  - Information Collected From Minors. Our Services and Websites are not directed at, or intended for use by, minors under the age of 18 and we do not knowingly collect Personal Information from anyone under the age of 18. Children should always get permission from a parent or guardian before sending personal information over the Internet. If you believe your child may have provided us with personal information, you can contact us and request that we delete the information. You can find more information about protecting children’s privacy by contacting the FTC or viewing its website at www.ftc.gov.
3. How We Use Your Information. We use the Information we collect for legitimate business activities, including: to provide and improve our Services; to communicate with you; to generate De-identified Information, and for advertising, marketing and recommendations purposes.
  - To Provide and Improve Our Services. We use the Information we collect, including Personal Information, to conduct business activities such as account administration, service provisioning, operations, billings and collections, marketing, analytics, customer service, technical support, network performance management, and fraud prevention. These purposes may specifically include:
    - establishing your account;
    - measuring credit and payment risk;
    - facilitating billing and collections functions and obligations (including any reporting to credit bureaus or collection agencies to obtain payment for our billed products and services);
    - authenticating access to your account;
    - account administration;
    - service delivery and optimization;
    - maintenance and operations, including management of the network and devices supporting our service and our systems;
    - technical support;
    - hardware and software upgrades for devices and systems;
    - understanding the use of the Services;
    - improving our Website and Services and identifying and developing new features, products and services;
    - providing you with programming, services and advertising that are of enhanced value and interest to you;
    - customer service, including processing and responding to your inquiries and troubleshooting;
    - internal analytics and reporting;
    - protecting our rights, personnel and property;
    - detecting the unauthorized reception, use or abuse of any Service and to protect our subscribers from fraudulent, abusive or unlawful use of, of subscription to, any Service;
    - enforcing our legal rights, including under our General Terms and Conditions of Service; and
    - complying with applicable law.
  - To Communicate With You. We use the Information we collect to deliver and personalize our communications with you. For example, we may use the Personal Information you provide us to inform you of Service updates or the status of a service request or outages, as well as to invite you to participate in a survey, to collect amounts you owe, or in connection with other activities related to the Services or your account.
  - To Generate De-identified Information. We may use Customers’ Personal Information to generate De-identified Information that cannot be reasonably linked to the Customer individually. Subject to Section 8 below, our collection, use, and disclosure of De-identified Information is subject to our discretion and is not subject to any of the restrictions in this Privacy Policy. For example, we may use De-identified Information for purposes such as measurement of viewership of programming and advertising, creation of tuning and viewing cohorts or segmentations, providing targeted content for our services or facilitating delivery of relevant third party advertising/promotional messages through our Services and on third party websites and other platforms. However, we do provide you with the choice to opt out of the use of your De-identified Information to facilitate Targeted Third Party Advertising (see Section 5.c below).
  - To Provide Advertising, Marketing and Recommendations. Subject to Section 8.b, we use the Information we collect about Customers and their use of Internet Services to make program and content recommendations, to send promotional communications about the Services or other SureStream product and service offerings, and for other First Party Advertising and Third Party Advertising purposes. These promotional communications and advertisements may be directed to you because you subscribe to these Services, because of the way you use these Services, or because you live in a certain geographic area, or may be based on demographic and interest information that we collect or obtain from other sources. For example, we may use Information to facilitate the display of First Party Advertising to you on other websites, mobile applications and devices.When we do this, we may provide Service Providers with access to certain Personal Information in order to facilitate the creation of de-identified audiences (for example, based on IP address, cookie ID, device ID or other persistent identifiers) and the placement of Targeted First Party Advertising. We may also use information collected from Website Users, such as IP address, to facilitate the display of First Party Advertising to those Users on other websites, mobile applications or devices. If you are an internet subscriber, we may also use Service Providers to create similar audiences based in part on de-identified viewing or usage data, deidentified demographic or interest data, and/or the IP address(es) we assign to facilitate the sending of Targeted Third Party Advertising that we think may be of interest to you. When we do so, we maintain and use the information in deidentified form, take reasonable measures to ensure that it cannot be associated with a Customer, and do not attempt to reidentify the information except as permitted under applicable law. Our sharing of information to facilitate Targeted Third Party Advertising is described in Sections 4.b and 4.c below. You can opt out of certain marketing messages as outlined in Section 6 below.
  - CPNI Data. Our use of VoIP CPNI data is limited as described in Section 8.b below.
  - Geolocation Data. We use service address, device and/or access point location data for a variety of purposes, including to facilitate emergency services, provide our services and our location-based applications and services. Where we offer our own location-based applications, we provide you with notice and choice about whether specific location-tracking features available on your device are turned on. Many types of wireless applications and services use device location data, including applications provided by other companies and wireless device operating systems. When you are considering new third party applications or services, you should carefully review the location-based services’ or application providers’ privacy policies to learn how they collect and use your information.
4. WHEN AND TO WHOM WE DISCLOSE INFORMATION..
  - General Disclosure Policy. Except as set forth below, SureStream will not disclose Customers’ Personal Information to a third party unless it is necessary for us to render our Services or conduct a legitimate business activity related to the Services we provide to you, or the Customer provides appropriate consent in advance. We do not sell information that personally identifies our Customers, including their internet usage information, video usage information or call detail records, to third parties for their own use, such as marketing or advertising of their own products and services.
  - Service Providers. We sometimes provide access to Information, including Personal Information, to Service Providers to assist us in providing Services or for other legitimate business purposes, including those described in Section 3.a. For example, we may provide access to certain Information to companies providing services to us, including installation and repair, billing, call center, sales and marketing, market research, fulfilment, mailings, data storage, data scrubbing, data analytics and processing, bill collection, auditing and accounting, credit reporting, and legal services. We may also provide access to third party data service providers who assist us in facilitating or providing Targeted Advertising by generating De-identified Information based on your Personal Information. These Service Providers are authorized to use your Personal Information only as necessary to provide these services on our behalf. We may also disclose Personal Information to credit reporting agencies. When you purchase a device from us, we may disclose your Personal Information and Financial Information with trusted Service Providers involved in fraud prevention in order to verify the authenticity of your transaction. Transactions detected as being potentially fraudulent may be further reviewed or declined.
  - SureStream Affiliated Businesses. We may disclose Information, including Personal Information, with SureStream affiliates that assist us in providing Services. We do this either to provide and improve our Services as described in Section 3.a above or to better enable those affiliates to provide their products and services to you. We may also disclose your information with other SureStream affiliates for First Party Marketing purposes, provided that any required consent (such as with respect to the use of CPNI data) is obtained.We may also disclose Customer and Website User Information, including Personal Information, with a successor company or other SureStream entities in the event of a merger, acquisition or sale of all, or components of, our business.Our advertising business affiliates work with third party advertisers to run crossplatform (tv, computer, tablet, mobile device) Targeted Advertising campaigns. We may disclose De-identified Information, including device IDs, IP addresses or other unique IDs, with these affiliates to facilitate the creation of audience segments to receive this Targeted Third Party Advertising and for other advertising and marketing purposes.
  - Account Owners and Users. We may disclose any information about a Customer’s accounts and use of the Services and their features to the primary account owner after appropriate authentication. The primary account owner may also authorize other users to access information on the account, and that may include data about you and your use of the Services.
  - Mailing List Information. If you subscribe to a non-voice Service offered over our cable system (e.g., TV or Internet), we may rely on a special provision of law that allows us to disclose mailing-list information about you to marketing organizations, programmers and other businesses. Mailing-list information includes your name, addresses, and the non-voice services to which you subscribe. You can opt-out of our disclosure of mailing list information as described in Section 6.e below.
  - CPNI and Subscriber List Information. If you subscribe to our VoIP phone service, applicable regulations allow us to disclose subscriber list information. For example, we may give your name, address, and number to organizations who publish phone directories or who provide 411 services or similar public services. We may transmit your name and number so that the person you call can see such information on his or her Caller ID. Certain procedures allow you to block transmission of Caller ID information. You may contact us to obtain additional information about these procedures. We may also transmit your name, number, and registered location to a public safety answering point (“PSAP”) when you dial 911 for emergency services. Disclosure of CPNI data is subject to additional specific limitations, as described in Section 8.b below.
  - Authorized Parties With Your Consent. We may disclose Personal Information about you to third parties with your consent. We may obtain your consent through a variety of channels, such as in writing, online, on your phone, when you agree to terms of service, in our stores, or implicitly, for example, when you purchase a product and ask that it be shipped to your home, thereby consenting to our disclosure of your name and address to a third party shipping company to complete delivery. Consent may also be obtained when you purchase additional services or features of SureStream Services that are provided via third parties.
  - Third Parties for Marketing Purposes. We do not and will not sell, license or rent Customers’ or Website Users’ Personal Information to unaffiliated third parties without the required consent to do so. We or our advertising business affiliates may provide De-identified Information (which may include information about viewing habits, demographic data, geolocation and system interaction) to third party advertisers, programmers audience measurement and research firms to provide more relevant programming, advertising and features, to improve the Services, to provide you with information or offers about products or services we believe may be of interest to you, or to assist third parties with media, programming and content planning, and purchasing efforts. We may also disclose De-identified Information or aggregate Information with third parties for other uses of their own provided they commit not to re-identify the information. Note: Data obtained through the SureStream Text Alert Notifications program will not be disclosed with any third parties for their marketing reasons/purposes.
  - When Required by Law or to Protect SureStream or Others. You agree that we may access, preserve and disclose your Information, including your Personal Information, your account information and content if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to:
    - - comply with legal process;
      - enforce our Terms of Service, Privacy Policies, or other contracts with you;
      - respond to claims that any content violates the rights of third parties;
      - respond to your requests for customer service;
      - respond to inquiries from government agencies regarding customerinitiated complaints provided to such agencies; or
      - protect the rights, property or personal safety of SureStream, its agents and affiliates, its users and the public.
    We may also disclose information to law enforcement agencies in emergency circumstances, where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law. We are required by law to report any evidence we may become aware of relating to violations of laws concerning child exploitation. In some areas we provide home security services, including video surveillance services. We provide information to emergency responders for purposes of providing this service. As a part of these services, we may record and store video at your direction and for your use. Our employees and agents have access to recorded video, and they may view that video during installation, while troubleshooting, when performing maintenance, and/or during emergency situations (as determined by us in our reasonable discretion). Consistent with the requirements found in the Cable Communications Policy Act of 1984 (“Cable Act”), the Electronic Communications Privacy Act (“ECPA”), the Digital Millennium Copyright (“DMCA”) and other federal laws, we may disclose information to representatives of government or other authorized persons. A private party may also use a subpoena under the DMCA to require our disclosure of a subscriber’s information when the party believes the subscriber has infringed on the copyright of such party. Upon receipt of the subpoena, we are required to identify the alleged infringer, without any notice to such subscriber.
5. HOW LONG WE KEEP INFORMATION. We generally keep some or all Customer and User Information for as long as necessary for the purpose(s) for which it was collected or other business, tax or legal purposes. When information is no longer needed or required to be maintained, we destroy or de-identify it in accordance with our internal policies.
6. CHOICES YOU HAVE TO LIMIT USE AND DISCLOSURE OF INFORMATION..
  - Marketing Communications. We may send you marketing communications about SureStream products or services. We allow you to limit or opt-out of some types of marketing communications. For example, you may choose not to receive promotional or marketing telephone calls or postal mailings regarding our Services by contacting us at 469 925-0001 for placement on our “Do Not Call” list or “Do Not Mail” list. Please note, any requests to be placed on the “Do Not Mail” list will only be effective for the 12-month period following such request. If you wish to continue to remain on the “Do Not Mail” list, you will need to make another request upon the expiration of the previous request. Please also note, “Do Not Call” and “Do Not Mail” requests may take up to thirty (30) days to become effective.
  - Interest Based First Party Advertising. Some advertising that you see on the internet or in mobile applications on your devices are tailored to your interests and based on your activity online or in the mobile applications. If you do not wish to receive interest based ads for our products and services on other websites or mobile applications, you may opt out of most such advertising by going to the following websites operated by industry trade and self-regulatory organizations: http://networkadvertising.org/choices (operated by the Network Advertising Initiative) or http://www.aboutads.info (operated by the Digital Advertising Alliance).
  - Targeted Third Party Advertising. We offer our Customers a choice as to whether they wish to receive Targeted Third Party Advertising based on their Information or use of the Services as described in Section 3.d. You can exercise this choice by contacting us at 469 925-0001. Please note, your choice may not take effect immediately and does not retroactively apply to existing advertising/promotional messages or campaigns.
  - Mailing List Information. If you do not want us to disclose mailing list information, please contact us at 469 925-0001. After your opt-out takes effect, we will limit our disclosures of your mailing list information to the other disclosures described in this Privacy Policy, which are permitted by other provisions of law.
7. How We Secure Your Information. We employ physical, electronic, and procedural safeguards to protect Customers’ Information. For example, we utilize secure socket layer (SSL) encryption to protect certain information you provide to us; employ verification measures to protect e-mail during delivery; maintain certain Customer databases in restricted areas; and secure the content by use of firewalls and other security methods. We also limit access to databases containing Customers’ Personal Information to specifically authorized employees and agents and other parties identified in Section 4 above. Despite these measures, we do not guarantee the security of information stored in our databases or that unauthorized parties will not intercept information you send or receive over the Internet. As a shared resource, the Internet subjects our services and you to the risk of unauthorized access to files and data, even when security measures are implemented. If you use the SureStream Internet service to send, receive or post personal or confidential information, you do so at your own risk. Since we cannot control websites or Internet services operated by third parties that you may visit through use of our Services, we recommend that you review the terms of service and privacy policies of those websites and services.
8. SPECIAL RULES AND RIGHTS UNDER FEDERAL LAW.
  - Cable Act and Personal Information. While we do not believe The Cable Act applies to SureStream, it imposes limitations with respect to the collection and disclosure of certain Personal Information by cable operators, unless you provide consent to collect or disclose information in another fashion, such as by accepting this Privacy Policy as part of the sign-up process for our Services. Generally speaking, cable operators may not use the cable system to collect personal information concerning Customers without their prior consent except to obtain information necessary to render cable service or other services to Customers or to detect unauthorized reception of cable communications. In addition, subject to certain specified exceptions, cable operators generally may not disclose personal information without consent of the subscriber concerned. Also, cable operators must take such actions as are necessary to prevent unauthorized access to such information by a person other than the subscriber or cable operator. In addition, if anyone asks a cable operator to provide information about you, the cable operator may have to notify you.
  - Communications Act and CPNI. Under federal law, you have a right as a VoIP phone Customer, and we have a duty, to protect the confidentiality of your CPNI data, including but not limited to, information such as the phone numbers you call; the frequency, duration, and timing of calls; billing information; and any services you have purchased. We restrict access to your CPNI by requiring a SureStream ID and password to access information about the calls you make. All other CPNI is similarly restricted by requiring a password and/or by requiring that you provide certain non-public verification information over the phone to confirm your identity. A written request may also be used to obtain your CPNI. You must send the written request to SureStream at Attn: Legal/CPNI, 550 N Central Expy, #176, McKinney, TX 75070. All requests will be verified. SureStream also restricts the use of your CPNI. Unless we have your appropriate consent, SureStream does not disclose your CPNI to non-affiliates for marketing purposes. We may, however, use telephone CPNI or disclose de-identified information to tailor your service and to market related SureStream products and services to you.
9. CHANGES TO THIS PRIVACY POLICY. We may change this Privacy Policy at any time. We will notify you of material changes by posting the revised Privacy Policy on the website. We encourage you to periodically review the Privacy Policy to inform yourself of any changes. The revised Privacy Policy will be effective on the date it is posted unless the revised notice states otherwise. You understand and agree that, if you use the Services after the effective date of the updated Privacy Policy, SureStream will consider your use as acceptance of the updated Privacy Policy. If we make material changes that will result in a new use, disclosure, or permission of access to Personal Information previously collected, we will obtain your appropriate consent before implementing such change as required by applicable law.
10. HOW TO CONTACT US. Please contact us if you have any questions about this Privacy Policy:
  SureStream LLC
  550 N Central Expy,
  #176 McKinney, TX 75070

Effective: February 20, 2023