For Cable Television, Broadband Internet, and Phone Services

Services furnished to Hiawatha Broadband Communication’s (HBC) cable subscribers are governed by Section 631 of the Communications Act of 1934, as amended, (the “Telecom Act”) and the Communications Cable Act of 1984, as amended, (the “Cable Act”). Pursuant to applicable Federal regulations, HBC is required to inform its subscribers of its policies regarding the collection, maintenance and disclosure of Personally Identifiable Information (PII) by cable television providers. This notice describes: (1) the nature of Personally Identifiable Information (PII) we collect and the limitations imposed by the Cable Act upon cable providers in the collection and disclosure of Personally Identifiable Information (PII) about its subscribers: (2) the nature of our use of Personally Identifiable Information (PII); (3) the nature, frequency and purpose of any disclosure which we may make of such information, including the types of persons to whom we may disclose the information; (4) the period during which we maintain Personally Identifiable Information (PII); (5) the times and place at which Personally Identifiable Information (PII) can be accessed; and (6) your rights under the Cable Act concerning Personally Identifiable Information (PII) and its collection and disclosure.

PII identifies a particular person; it does not include aggregate data that does not identify a particular person or persons.

In addition, Section 222 of the Telecom Act provides additional privacy protections in connection with the Company’s Phone services and Broadband Internet Access Services (BIAS) and its use of Customer Proprietary Information and Customer Proprietary Network Information (CPNI). The Telecom Act describes CPNI as (i) information about the quantity, technical configuration, type, destination, location and amount of use of the Phone services; and (ii) information contained on a telephone bill concerning the Phone services being received. This notice describes HBC’s CPNI policy, the types of CPNI information that is obtained from the Company’s traditional voice and VoIP Phone service subscribers, and how that information is used and protected.

Pursuant to the FCC’s 2015 Open Internet Order, broadband Internet access service (BIAS) offered by HBC on a retail, mass-market basis has been reclassified as a “Telecommunication service”.

As a Telecommunications service, HBC also has an obligation to protect the privacy of BIAS subscribers. This notice therefore also serves to describe HBC’s policies to protect the privacy of its BIAS subscribers and the use of a subscribers Personally Identifiable Information (PII).

HBC won’t sell your Personal Information

The FCC passed legislation that allows Internet Service Providers to sell their customers’ web browsing history. This goes against the corporate values of HBC as we are strong proponents of the privacy of our customers.  HBC has never sold customer information and does not plan to do so no matter what the legislation allows.

Collection of Personally Identifiable Information (PII), Customer Proprietary Information and CPNI

Personally Identifiable Information (PII) that has been furnished to HBC or HBC has collected by virtue of the provisioning of cable, Internet or Phone services is described herein. PII is information that is linked or can be linked to a customer or its device. The FCC’s rules prescribe for the protection of a customer’s “Sensitive” and “non-Sensitive” personal information. Sensitive Customer Proprietary information includes a customer’s financial information, health information, information pertaining to its children, a customer’s social security information, precise GEO-location information, content of a customer’s communications, call detail information, web browsing history, and applicable usage history.

This notice pertains solely to the collection of PII, Customer Proprietary Information and CPNI information that is used, disclosed or accessed in connection with the Company’s provisioning of cable television, Broadband Internet, and Phone services. It does not cover information that maybe collected in connection with the company’s provisioning of other products and services. Please refer to the terms and conditions associated with other products and services to learn how personal information is handled.

Purposes for which HBC may Collect Personally Identifiable Information (PII) Customer Proprietary Information and CPNI

As a cable operative, HBC may use the cable system to collect Personally Identifiable Information (PII) concerning any subscriber in order to render our cable service or other services to our subscribers; and (ii) detect unauthorized reception of cable communications. The Cable Act prohibits HBC from using the cable system to collect Personally Identifiable Information (PII) concerning any subscriber for any purposes other than those listed above without the subscriber’s prior written or electronic consent.

The Telecom Act authorizes HBC to use, disclose, and permit access to individually identifiable CPNI in the provisioning of our telecommunication services from which such information is derived; and the provisioning of services that are necessary to, or used in, the provisioning of these services, including the publishing of directories. The Telecommunication Act prohibits HBC from using CPNI for any other purpose that those that have been stated herein without a customer’s approval except as permitted or required by law.

What kind of Personally Identifiable Information (PII), Customer Proprietary Information, and CPNI is collected by HBC?

Personally Identifiable Information (PII) may be collected at several different points when service is initiated. Personally Identifiable Information (PII) does not include aggregate data or other data that does not identify a particular subscriber such as, demographic information that does not identify a specific individual or household or information, which by itself, is not specific to an individual subscriber, such as a subscriber’s specific GEO-location, gender, its IP address, MAC address or other equipment identifiers.  Personally Identifiable Information (PII) that HBC does collect from its subscribers includes a subscriber’s (i) name; (ii) service address; (iii) billing address; (iv) email address; (v) telephone number; (vi) driver’s license number; (vii) social security number; (viii) bank account number; (ix) credit card; and other similar account information.

Examples of CPNI that Company collects from its Phone subscribers includes information derived from the provisioning of service such as a customer’s (i) service location; (ii) technical configuration of service; (iii) type of service; (iv) quantity of service; (v) amount of use of service; (vi) calling patterns; (vii) other information contained on customer bills for local and long distance services.

CPNI does not include “subscriber list information”. The Company may also collect and maintain other information about a customer’s account. Examples of such information include (i) billing, payment and deposit history; (ii) additional service information; (iii) customer correspondence and communication records; (iv) records indicating the number of television sets, set-top boxes, modems, or telephones that are connected to our system and (vi) additional information about the service options you have chosen.

During the initial provisioning of services and during any subsequent changes or updates to our services, HBC may collect technical information about your televisions, any set-top boxes, computer hardware and software, cable modems, telephones, and or other cable or other service related devices along with any customized settings or preferences.  Also, if you rent your residence, we may have a record to whether the landlord permission was required prior to installing our services that along with the landlord’s name and address.

The kind of Information we Collect with our Cable System and Equipment

When a customer uses our interactive or other transactional service such as Video-On-Demand or Pay-Per-View or online content, our system as example, may automatically collect certain information about the use of these services.  A majority of this information is not personally identifiable, but is simply used to administer a particular request that is being made by use of a remote control, set-top box, VCR, computer, remote access device or other equipment.  Examples of this may be changing your television channel, review listings in an electronic guide, pause or fast forward through certain Video-On-Demand programming, and/or invoking a calling feature on the Phone service.

However, in order to carry out a request that is made by the subscriber to watch a Pay-Per-View program(s), purchase a product, service or feature, our system may collect certain Personally Identifiable Information (PII).  This type of information consists mainly of account and billing-related such as Pay-Per-View or Video-On-Demand programs or other such products, services or features ordered so that customers can be properly billed for those services.

In addition, anonymous and aggregate information using set-top box or other equipment may be collected. This type of information has been stripped so that no customer can be identified. Such that might be collected are based on programming viewership (things like number of times a program is watched per date, average length of time a program is watched and how many people might be watching a program), whether people are watching commercials. This type of non-Personally Identifiable Information (PII) can be shared with third-parties, including advertisers, content providers, data companies, rating agencies, audience measurement, and research firms.

Use of Personally Identifiable Information (PII), Customer Proprietary Information and CPNI

HBC collects, maintains and uses Personally Identifiable Information (PII), Customer Proprietary Information and CPNI as permitted by the Cable Act and Telecom Act and other applicable laws. This information is used primarily to conduct business related activities related to providing subscribers with cable and other services and to assist us in identifying theft of service. We use Personally Identifiable Information (PII), customer proprietary information and CPNI in connection with: (i) billing, invoicing and credit verification; (ii) administration; (iii) surveys; (iv) collection of fees and surcharges; (v) marketing of services within the same class of a customer’s subscribed services; (vi) service delivery and customization; (vii) maintenance and operations; (viii) technical support; (ix) hardware and software upgrades, and; (x) fraud prevention.

Specifically we may also use Personally Identifiable Information (PII), Customer Proprietary Information and CPNI to (i) install, configure, operate, provide support, and maintain our cable and other services; (ii) investigate your credit history a credit report or other similar information or by making inquiries of account history; (iii) confirm you are receiving the level(s) of service being requested and are properly billed; (iv) identify the customer when changes are being made to their account; (v) detect unauthorized reception, use or abuse of our services; (vi) determine whether there are any violations of any applicable policies and terms of service; (vii) manage the network supporting our services (ix) configure cable and other service related devices; (x) authenticate (or allows other to authenticate) your right to access certain services, including Online content; and (xi) comply with law.

The Telecom Act further permits HBC to use, disclose, and permit access to Customer Proprietary Information and CPNI obtained from our subscribers, either directly or indirectly, to (i) initiate, render, bill and collect for telecommunication services; (ii) protect our rights and property, and protect our users of these services and other carriers from fraudulent, abusive or unlawful use of, or subscription to these services; (iii) We are also permitted to access CPNI: (i) for the purpose of providing or marketing service offerings among the categories of service to which you already subscribe; (iii) in our provisioning of inside wiring, installation, maintenance and repair services; (iv) to market certain services to subscribers of basic Phone service (formerly known as adjunct to basic service) such as speed dialing, computer-provided directory assistance, call monitoring, call tracing, call blocking, call waiting, caller ID, call forwarding, and other such features.

HBC may not use a subscriber’s CPNI to market products and services to a subscriber other than services that are within the same category of service to which the customer subscribes without a customer approval.  Such approval may be secured through the policies described below.

Privacy Policies Specific to Subscribers of HBC’s Broadband Internet and Phone Services

HBC may collect and store for a period of time, personally identifiable and non-Personally Identifiable Information (PII) from customers who subscribe to the Company’s high-speed Internet and Phone services to: (i) send and receive email, video mail and instant messages; (ii) transfer and share files; (iii) make files accessible; (vi) visit websites; (v) place or receive calls; (vi) leave and receive voicemail messages; (vii) establish custom settings for preferences; (viii) communicate with us for support; or (ix) otherwise use the services and their features.

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