Effective Date: July 1, 2012
IM Telecom LLC (“Infiniti Mobile®“) is dedicated to providing superior customer satisfaction and is committed to protecting customer privacy. We take this responsibility seriously as a key component to earning and maintaining our customers’ trust.
- Collection of your Confidential Personal Information
- Use of your Confidential Personal Information
- Sharing of your Confidential Personal Information
- Accessing your Confidential Personal Information
- Security of your Confidential Personal Information
- Customer Proprietary Network Information (“CPNI”)
- Personally Identifiable Wireless Location Information
- Communication Preferences
- Enforcement of and Changes to this Privacy Statement
- Contacting Us
This Privacy Statement applies to Infiniti Mobile and any Affiliate with whom we share or collect Confidential Personal Information. Affiliate refers to any of the Telephone and Data Systems, Inc. owned family of companies. This Privacy Statement also addresses the Third Parties who we require to maintain appropriate privacy and security measures consistent with this Privacy Statement when we share your Confidential Personal Information with them. We use “Third Parties” to refer to agents, vendors, suppliers, subcontractors, and independent contractors with whom Infiniti Mobile or its Affiliates have a business relationship. By subscribing to our services or accessing our websites, you agree to our collection and use of your information as described in this Privacy Statement as may be amended from time to time. This Privacy Statement does not apply to services, products, or websites that do not display or link to this Privacy Statement or that have their own privacy statements.
We use the term “Confidential Personal Information” broadly to mean all information that relates to you and identifies or can be used to identify you. This information includes your name, billing address, social security number, driver’s license number, credit card number, bank account number, e-mail address, and credit information. It also includes information that we have about you by virtue of our relationship with you as your wireless service provider, otherwise known as Customer Proprietary Network Information (“CPNI”).
Infiniti Mobile may collect Confidential Personal Information for the purposes specified in this Privacy Statement and as otherwise permitted by law. We may also collect this information about you from our Affiliates and Third Parties with whom we have a business relationship. We may collect Confidential Personal Information through retail stores, over the phone, or online. You may choose to provide this information to us through a number of interactions such as by
- Ordering a product or service from us
- Sending us an email
- Registering to receive information about our products or services
- Applying for a job or a grant
- Entering a contest
- Using our website
We may ask you questions to better serve your special needs and interests. For example, we may ask whether you work at home, whether any members of your household have special needs or whether teenagers reside in your household in order to determine whether you may be interested in certain services. We may also monitor or record our calls with you for training, quality assurance, or other business purposes.
Confidential Personal Information is not required to establish Prepaid Wireless service. However, customers are encouraged to provide valid information such as name and address when establishing an account so that we may serve the customer better in the future. In absence of verifiable and valid Confidential Personal Information, customers may have access only to limited account information and will not be able to receive call detail information.
We may use technologies such as cookies, web beacons, and similar technologies to collect, store and read information on your computer or mobile browser when you visit one of our websites. Cookies are small chunks of data created by a web server, delivered through a web browser, and stored on your computer. They provide a means for websites that you visit to keep track of your online usage patterns and preferences, as well as identify you as a return visitor. Cookies make the personalization of your web experiences possible so that you do not need to re-enter your information from scratch upon each visit to a given website. web beacons consist of a small string of software code on your browser that works with cookies to monitor website usage and can be used to personalize online advertising.
We may collect and log on our servers information that your browser sends whenever you visit a Infiniti Mobile website. These “server logs” typically include your web request, Internet Protocol address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser. We may combine the information collected from our websites with your Confidential Personal Information in order to provide a more efficient, interesting and customized online experience to you and to provide advertising about goods and services that you may find of particular interest.
Online advertisers may also place cookies on your computer or mobile device when you are on a Infiniti Mobile website to collect the preferences you demonstrate through your online activities on our websites and use them to provide personalized advertising that may be of interest to you when you are on other websites. For purposes of this section, these online advertisers are called Third Party Advertisers. Infiniti Mobile adheres to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising, and it only uses Third Party Advertisers that have pledged their adherence to these principles. To find out more information about online behavioral advertising or to opt-out of the collection and use of your online information by Third Party Advertisers for online behavioral advertising, click here.
You may be able to disable cookies on your computer or mobile device; however if you do so, you may limit your experience, including finding pricing and availability of products and services in your area from our website. You can set your browser to delete cookies or to tell you before you accept one. Look in your browser’s Options or Preferences menu. You may not have the ability to opt-out of or disable cookies on certain mobile browsers that you use with your mobile device.
Infiniti Mobile does not track user click stream or other information resulting from activity on sites that are not operated by Infiniti Mobile.
Collection and Use of Children’s Confidential Personal Information
Infiniti Mobile’s websites and services are intended for general audiences. In order to respect the privacy of children online, Infiniti Mobile does not knowingly collect, maintain or process Confidential Personal Information submitted by children under the age of 13. When one of our websites does collect age information, and users identify themselves as under 13, the site will block such users from providing Confidential Personal Information.
We may use your Confidential Personal Information to provide you with and manage the services you request, communicate with you to maintain good customer relations or to suggest new products and services that may be of interest to you, personalize the content we deliver, conduct industry or consumer surveys, manage, improve and troubleshoot our network and services, enforce our Terms of Service, or for any purpose otherwise permitted or required by law.
When you want to set up an account with Infiniti Mobile, in order to determine your credit worthiness, we use some of your Confidential Personal Information to request a credit report from a credit-reporting agency, as specified in the Infiniti Mobile Service Agreement.
Infiniti Mobile uses the information collected on its websites to provide you with the products, services, and information you requested. When you use our websites to order products or services, or to request information about them, we may use the information we have about you as we would use the same information obtained offline – for example, to evaluate your service needs and contact you regarding additional services you may find useful. You may also submit applications for employment online, and we will use the information you provide to consider you for employment.
There may be instances when Infiniti Mobile may access or disclose Confidential Personal Information without notice or your consent in order to: (i) investigate, protect or defend the legal rights or property of Infiniti Mobile, its Affiliates and others (including enforcement of our agreements); (ii) protect the safety and security of customers or members of the public including acting in urgent circumstances; (iii) protect against fraud or for risk management purposes; or (iv) comply with the law or legal process such as a subpoena.
If we obtain Confidential Personal Information from an Affiliate or Third Party, our use of that information is also governed by this Privacy Statement.
We will not disclose your Confidential Personal Information without your express or implied consent outside of Infiniti Mobile, its Affiliates, or Third Parties other than as described in this Privacy Statement.
Infiniti Mobile may share certain Confidential Personal Information for purposes permitted by law without your consent such as to help initiate, render, bill, and collect for its products and services; as well as to provide and market Infiniti Mobile products and services and co-branded products and services.
Infiniti Mobile may share your CPNI with Affiliates and Third Parties with your consent for the purposes of marketing products and services. Depending on the circumstance, we may use notice and opt-out to obtain your consent.
Affiliates and Third Parties are permitted to use only the Confidential Personal Information they need and are prohibited from using it for any purpose other than those for which they are contractually bound to Infiniti Mobile, permitted by law, or with your consent. When we use such entities to assist us in processing your Confidential Personal Information, we require that they maintain appropriate privacy and security measures consistent with this Privacy Statement.
Infiniti Mobile does not sell your Confidential Personal Information for any purpose other than to enforce our rights under the Terms of Service or as expressly stated in this Privacy Statement. For example, we may sell past-due accounts receivable in an effort to collect for unpaid services. In addition, if Infiniti Mobile were to sell all or part of its business or makes a sale or transfer of all or a material part of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, Infiniti Mobile may transfer your Confidential Personal Information to the other party or parties involved in the transaction as part of that transaction.
Infiniti Mobile does not publish or support directories of our customers’ wireless phone numbers nor do we make this information available for listing in public directories.
California Privacy Rights
A business subject to California Civil Code section 1798.83 is required to disclose to its customers, upon request, the identity of any other party to whom the business has disclosed “personal information” regarding that customer within the immediately preceding calendar year.
If you are a California resident and would like to make such a request, please submit your request in writing to:
Attn: Director of Privacy
1855 East 15th Street
Tulsa, Oklahoma 74104
Please note that California businesses are only required to respond to a customer request once during the course of any calendar year.
Infiniti Mobile takes reasonable measures to assure that the Confidential Personal Information we use about you is accurate, complete, and up-to-date. We make good faith efforts to provide you with access to your Confidential Personal Information either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.
Customers who wish to review and/or edit their Confidential Personal Information may do so by contacting us at the number provided on their billing statement, visiting a retail store, accessing their information online through My Account, or by contacting us via e-mail.
We may decline to process requests for information that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
Infiniti Mobile provides customers with the ability to authorize individuals (“Authorized User”) to make inquiries, limited changes, or both, in order to maintain their account. Customers may specify the type of information and changes that the Authorized User is approved to request. This includes access to call detail and text message detail. An Authorized User cannot change the customer’s Confidential Personal Information. Customers may add or remove an Authorized User from their account at any time.
Customers should inform other users of the services on their accounts that Customers and Authorized Users have access to the call and messaging detail, data usage detail, and location information resulting from the usage of these services. Using services on the account of another Customer implies consent to have that usage revealed to the Customer and that Customer’s Authorized Users.
We ask customers and their Authorized Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests. If you or your Authorized User contacts us via phone, you will be asked to provide information in order to authenticate you as an authorized party on the account before we are able to assist you with account information. You or your Authorized user will be asked to present a valid government issued photo ID when requesting account information while at a retail store.
Access to call detail or text message detail is available only by registering for online access to billing information through My Account, calling and requesting a copy to be sent to the customer’s billing address of record, or obtaining a copy by visiting one of our company owned retail stores. Customers may add call detail or text message detail to their future billing statements if they are not currently receiving this information. Call detail or text message detail will never be provided over the phone.
Infiniti Mobile takes reasonable security safeguards to protect against such risks as loss or unauthorized access, destruction, use, modification, or disclosure of Confidential Personal Information.
We restrict access to Confidential Personal Information to those who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
We protect the security of your Confidential Personal Information transmitted through our websites by using software which encrypts the Confidential Personal Information you input or view.
Customers are encouraged to establish a password on their account for added account protection. Passwords should be updated on a regular basis. A customer may add or change their password over the telephone or at a retail store location after providing identification information.
Customers should not provide their account information or password to anyone other than Authorized Users on their account. Customers are encouraged to protect their wireless device, computer, and passwords against unauthorized access. When accessing information online, customers should sign off when finished using a shared computer and always log out of any website after viewing Confidential Personal Information.
We will not store Confidential Personal Information beyond what is necessary for business purposes, including for internal service evaluation and quality assurance purposes, except as otherwise required by law.
Controlling Unsolicited Text Messages and E-mail (“Spam “)
Infiniti Mobile is concerned about controlling unsolicited commercial text messages and e-mail or “spam.” While Infiniti Mobile continues to actively review and implement new technology to help prevent these activities, there is no currently available technology that will totally prevent the sending and receiving of unsolicited text messages or e-mail. Using junk e-mail tools and being cautious about the sharing of your e-mail address while online will help reduce the amount of unsolicited e-mail you receive. For more information about this and other related topics go to the Federal Trade Commission’s website at http://www.onguardonline.gov. You may also contact us via e-mail or write to us at the following address:
Attn: Customer Resolutions Support
1855 East 15th Street
Tulsa, Oklahoma 74104
CPNI refers to and includes information that we have about you by virtue of our relationship with you as your wireless service provider. This includes information about your account usage – such as the type and quantity of the services you subscribe to and other details about your calling, text messaging, or picture messaging plan. Call detail information includes the date, time, call-to location, number called or the number the call was received from, and minutes and charges of the call. Text or picture messaging detail includes the number the message was sent to or received from, date, and time the message was sent from your phone. Text or picture messaging detail does not include the actual message content. Use of CPNI is subject to federal laws and regulations with which Infiniti Mobile is required to comply.
We use CPNI to help us service your account when you call us with questions, to guard against fraudulent use of our network, to provision our services, or to generate and collect your bill. We may also use it to recommend other wireless products and services to you. For example, if you routinely exceed the minutes in your calling plan, we are able to use your calling records to recommend a calling plan that may be better suited to meet your needs. The CPNI rules recognize the value of our use of this information to serve you and permit our use of your information provided we safeguard it from unauthorized disclosure. We want to assure all of our customers that we have practices and procedures in place to help ensure your Confidential Personal Information is safe.
Infiniti Mobile is prohibited from allowing our Affiliates or Third Parties from using this information without your permission for marketing. Infiniti Mobile’s or its Affiliates’ products and services to you. Your permission allows them to use this information to offer suggestions about new wireless products and services to help you get more out of your existing wireless service, or to assist you with your other telecommunication needs. Third Parties have the same duty to safeguard your CPNI as we do.
When you become a customer of Infiniti Mobile and no later than every two years thereafter, we will send you a notice in the mail explaining your rights concerning Customer Proprietary Network Information (“CPNI Notice”). You can expect to receive the CPNI Notice in your bill or by a separate mailing if you have an online account or are a Pre-paid Wireless customer for whom we have Confidential Personal Information. It is important that you contact us as described in this notice if you do not wish to grant permission to our Affiliates and agents to use your CPNI to market new products and services to you. The law permits us to infer your permission if you do not tell us otherwise.
Access or Disclosure of CPNI
There may be instances when Infiniti Mobile may access or disclose CPNI without notice or your consent in order to: (i) protect or defend the legal rights or property of Infiniti Mobile and others (including enforcement of our agreements); (ii) protect the safety and security of customers or members of the public including acting in urgent circumstances; (iii) protect against fraud or for risk management purposes; or (iv) comply with the law or legal process such as a subpoena. In addition, if Infiniti Mobile sells all or part of its business or makes a sale or transfer of all or a material part of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, Infiniti Mobile may transfer your CPNI to the party or parties involved in the transaction as part of that transaction.
For additional information about the FCC’s rules pertaining to CPNI follow this link: http://www.fcc.gov/cgb/consumerfacts/phoneaboutyou.html
In order to provide you with wireless services, our network receives and tracks your location information so that we may route communications, deliver wireless content and properly bill you for your services. We may also disclose your location information with other parties as permitted by you or by applicable law, including but not limited to public safety, fire service or law enforcement officials in emergency situations, and to other parties which provide location-based services that track the location of the mobile device using our network with or without our cooperation. You should understand the risks involved in consenting to the disclosure of your mobile device’s location information before requesting a location based service and inform users to whom you provide your mobile device that his or her location can be tracked.
Infiniti Mobile uses a variety of commercially reasonable and appropriate safeguards to protect location information residing on our systems from unauthorized access or disclosure including, without limitation, server firewalls and physical facility security. We retain location information only so long as needed to provide location-based services or as required by law. Should we retain location information for a longer period, we shall do so only for business purposes and will convert such location information into aggregated or anonymized data. No security is perfect, however, and Infiniti Mobile cannot guarantee the security of your location information.
Infiniti Mobile does not guaranty the accuracy or completeness of location information delivered through its network, and any location-based service may be disrupted or fail due to environmental factors and factors affecting satellite usage.
Infiniti Mobile abides by the International Association for the Wireless Telecommunications Industry (“CTIA”) Best Practices and Guidelines for Location Based Services which can be found at the CTIA’s website at http://www.ctia.org
If you do not want Infiniti Mobile to use your Confidential Personal Information to contact you for marketing or solicitation purposes (excluding notices about your existing account), please contact us via e-mail or write to us at the following address:
Attn: Customer Resolutions Support
1855 East 15th Street
Tulsa, OK 74104
When writing to us, please specify which contact methods (phone calls, mail, bill inserts, text messages, or e-mail messages) you would prefer that we do not use to communicate to you for the purposes outlined above. Keep in mind that restricting contact methods may make it more difficult for us to keep you informed about new telecommunications products and services that can be of benefit to you. You can revoke these options at any time by contacting us using one of the methods provided.
These choices do not apply to the display of online advertising or the receipt of mandatory service communications that are considered part of certain Infiniti Mobile services, which you may receive periodically unless you cancel the service.
If you request to not be contacted by phone for marketing or sales purposes, please note that the Infiniti Mobile Do Not Call List restricts these types of phone contacts from Infiniti Mobile only, so you may continue to receive calls from other companies. If you would like to add your number to the National Do Not Call List, you may do so by calling 1-888-382-1222 or going online at www.donotcall.gov.
Our employees and those of our Affiliates are trained regarding their responsibilities to safeguard your privacy. They are required to adhere to a Code of Business Conduct, this Privacy Statement, and Infiniti Mobile’s policies which support our commitment to protecting customer privacy. Failure to comply with the Code, this Privacy Statement, or Infiniti Mobile’s policies may result in disciplinary action up to and including termination of employment or contractual agreements.
If our employees, Affiliates, or the Third Parties become aware of practices that raise privacy concerns, they are required to report them to their supervisors or to contact Infiniti Mobile’s Privacy Incident Response Team.
We will occasionally update this Privacy Statement to reflect changes in our services and customer feedback. When we post changes to this Privacy Statement, we will revise the effective date at the top of this Privacy Statement. If there are material changes to this Privacy Statement or in how Infiniti Mobile will use your Confidential Personal Information, we will notify you either by prominently posting a notice of such changes 30 days prior to implementing the change and may make reasonable attempts to notify you directly. We will give you a choice to opt-out of any retroactive material changes in our Privacy Statement. We encourage you to periodically review this Privacy Statement to be kept informed about Infiniti Mobile’s privacy practices.
Infiniti Mobile welcomes your comments regarding this Privacy Statement. If you have questions about this Privacy Statement, please contact us or write to us at the following address:
Attn: Director of Privacy
1855 East 15th Street
Tulsa, OK 74104