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Privacy Policy
Effective: 1 March 2005
General Privacy Guidelines
The GTA has strict policies governing employee access to customer records. We access customer accounts, records or reports for authorized business purposes only. We educate our employees about their obligation to safeguard customer information and telephone calls, and we hold them accountable for their actions.
Privacy is a priority for the GTA when we develop new products and services. The GTA conducts a privacy review as part of its product development process. We inform customers about any privacy implications of new products and services we introduce.
Your Personal Information
Personal information is any data directly associated with a specific person, such as the subscriber name, address, telephone number, e-mail address, location information, or online/network activities (e.g. log files of Web searching activities).
The GTA recognizes that parents may purchase our products and services for use by family members, including minors. Any information collected from such usage will be attributed to the subscriber (the parent or guardian). In accordance with the Children's Online Privacy Protection Act, the GTA does not design its products or services to collect personal information from children under the age of 13 years.
Our definition of personal information does not include aggregate information. Aggregate information is data we collect about a group or category of subscribers from which individual subscriber identities have been removed. In other words, information about how you use a service may be collected and combined with information about how others use the same service, but no personally identifiable information will be included in the resulting data. Aggregate data helps us understand trends and subscriber needs so that we can better consider new services or tailor existing services to subscriber desires.
The Information We Obtain, and How We Use It
The GTA obtains information about customers that helps us to provide service, and we use that information for business purposes only.
For example, we need to know your name, address and the services you buy from us. When you call us, a service representative refers to your customer record to serve you better. It also may be useful for us to know about your telephone bill, your calling patterns, and your have special needs. We may use that kind of information to offer you the most effective services for your particular needs.
Furthermore, we may use information in our records to protect customers, employees, or property (for example, to investigate fraud or harassment).
We want to make sure the information we obtain and use is accurate. Much of this information is reflected in your monthly telephone bill. If you see an inaccuracy on your GTA bill, let us know and then we can correct it.
‘Do Not Call’ Lists
The GTA regularly provides useful information about new products and services to our residential customers, including our customers with non-published telephone numbers. However, consumers who do not wish to receive such information can have their names removed from the direct mail and telemarketing lists that we use internally. For example, if you receive an unwanted telemarketing call from us, simply tell a GTA representative that you do not wish to receive future calls and ask to be placed on our ‘Do Not Call’ list. Please understand that making this request might mean that you will be unaware of services or discounts that you find useful.
Customer Service Call Monitoring
When you speak to a GTA representative, a supervisor might monitor that call. Supervisors listen in only to help train employees and ensure that we provide you with accurate information and consistent, high-quality customer service.
Disclosure of Information Outside the GTA
In general, the GTA will notify you and give you the option of not having your customer information distributed outside of our organization. We keep our records of the services you buy and the calls you make private, and will not ordinarily disclose this information to outside parties without your permission. However, we do release customer information without involving you if disclosure is required by law or to protect the safety of customers, employees, or property.
Here are some examples of how you can control the disclosure of information:
- You can tell us the telephone listings you want to include in our directories and in directory assistance. You can also choose a non-published number or a non-listed number, or exclude your address from your listing.
- We may compile lists of names, addresses, and telephone numbers from our published White Pages directories and provide the lists to qualified companies that are conducting product promotions. Non-published and non-listed numbers are not included in these lists, and we will remove other customers from these lists by request.
- All customers in areas where Caller ID services are available have the ability to block the display of their phone numbers and names. Caller ID blocking does not prevent the transmission of your phone number when you dial 911, or 800, 888, 877, and 900 numbers.
Here are some cases in which disclosure is required by law or to protect the safety of customers, employees, or property:
- When you dial 911, information about your location may be transmitted automatically to a public safety agency. Certain information about your long distance calls is transmitted to your long distance company for billing purposes. The GTA is also is required by law to give competitive local exchange carriers access to its customer databases for purposes of serving their customers, to exchange credit information with other carriers, and to provide published and listed numbers to directory publishers.
- The GTA must disclose information, as necessary, to comply with court orders or subpoenas. The GTA will also share information to protect its rights or property and to protect users of its services and other carriers from fraudulent, abusive, or unlawful use of services.
- The GTA may provide information to collection agencies about former customer accounts that are in arrears.
- Consumer information may become known to contractors working for the GTA. These contractors have the same obligations as our regular employees to protect customer information.
Your Telephone Account Information Rights
The FCC defines your telephone account information as Customer Proprietary Network Information (CPNI). Under federal law, you have the right to the confidentiality of your telecommunications service information and we have the corresponding duty to protect it. This information includes the type of line you have, technical characteristics, class of service, current telephone charges, long distance and local service billing records, directory assistance charges, usage data and calling patterns.
The GTA does not sell CPNI to unaffiliated third parties and abides by the federal and/or state CPNI rules that apply to all telecommunications carriers.
We may use this information, without further authorization by you, to offer you the following:
- Additional services of the type you already purchase from us.
- The full range of products and services available from the GTA and other GTA companies that may be different from the type of services you currently buy from us. In addition to local telephone services, the GTA and other GTA company services include long distance, wireless, and Internet services.
Use of your information in this way permits us to offer you a package of services tailored to your specific needs. Without further authorization by you, we may also share your information with other GTA companies with whom you already have an existing service relationship.
No action by you is necessary to permit us to use your information to offer you services in addition to those that you currently buy from us. However, before using your information for the first time, we will notify you by mail or through your account executive. You will have 30 days to tell us, using the toll free number mentioned in our notice, if you do not want us to use your information to offer additional services. After 30 days, the GTA may begin using your information to offer you additional services unless you have notified us that we may not use it for this purpose. However, you can change your decision at any time by calling the toll free number. Your decision will remain effective until you change it.
If you have any questions about the notice or would like to know how to restrict the use of your information, please contact the GTA customer service number on your telephone bill.
Providing Services to Enhance Your Privacy
Non-published numbers, Caller ID and Caller ID blocking services, and Anonymous Call Rejection are among the privacy-management services the GTA offers our telephone customers. We also work to develop other services that help customers to control access to information about them. We seek customer input in developing new products and conduct comprehensive customer outreach and education efforts before and after introducing privacy-sensitive products.
Wireless Privacy Guidelines
Presence, Location, and Tracking
The GTA’s wireless network is able to determine the general location of your phone or wireless device whenever it is turned on. Your wireless device sends out a periodic signal to the nearest cell tower so that the network can route an incoming communication correctly and properly bill for the service. Wireless communications are not possible without this kind of location capability.
If you dial 911 for emergency services, we may provide your network location (1) to an emergency medical service provider or emergency dispatch provider, (2) a public safety, fire service or law enforcement official, or (3) a hospital emergency or trauma care facility.
The law also permits us to disclose the location of a device on our network without a user's consent (1) to a user's legal guardian or members of a user’s immediate family in an emergency situation that involves the risk of death or serious physical harm, (2) to database management services or information providers solely to assist in delivering emergency services, or (3) to a governmental entity if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires or justifies disclosure of a device's location on the network without delay. Legally required upgrades will allow us to provide a location more precise than cell site location.
In addition, we offer optional services on our GSM/GPRS network that make use of your network location. Please review the terms and conditions for each service for additional information about how the location information will be used. The location used for these services is separate from the network location information when you make a voice call.
Your wireless Internet service may also be personalized using your ZIP code or other location identifiers. We use this information to serve you relevant content, and we treat the information like any other personal information under this Policy. This service does not use the network location technology described earlier.
Internet Privacy Guidelines
The GTA respects the privacy of everyone who visits our Web site, responds to our Web-based advertisements, or sends us email. The following statement outlines the information the GTA collects and explains how we use that information. It also tells you what to do if you do not want your personal information collected or shared when you visit our site, respond to our Web-based advertisements, or send us email.
Security
All purchasing and payment forms on this Website use an automatic Secure Socket Layer (SSL) or Secure Electronic Transaction (SET) protocol to provide secure and confidential transactions for you. Secure sessions are indicated by the letters ‘https’ in the address bar at the top of your browser. During a secure session, all information you type into a form, including confidential data, is delivered privately and unaltered to GTA’s servers. This security prevents other unauthorized companies and Web users from reading your information.
Personal Information
The GTA does not collect personal information about you (such as your name, address, social security number, telephone number, or email address) through its Web site unless you provide it voluntarily.
Following are some cases in which the GTA requires personal information:
- When you complete an online order for a product or service. If you do not want to complete an online order form, we will give you the option of calling a toll free phone number to complete the order.
- When you enter an online contest or sweepstakes. If you do not want to complete an online contest or sweepstakes form, we will mail an entry card to your address.
- When you request information about GTA products or services.
If you do not want personal information collected, please do not submit it to us through our Website. If you have already submitted this information and want it updated or removed from our records, please contact us. We will use reasonable efforts to update or delete your information as appropriate.
When you do provide us with personal information, we might store and process that information for the following purposes:
- Achieving a better understanding of customer needs and how we can improve our products and services.
- Contacting you with promotional information and announcements if you have previously given your permission for us to contact you in this way.
- Contacting you with problems or questions about your account.
The GTA does not sell personal information to third parties. We might, however, share information with business partners that assist the GTA in providing you service. We give you the choice of whether or not your information is used for marketing purposes or shared information with our partners.
Children and Minors
In accordance with the Children's Online Privacy Protection Act, the GTA does intentionally collect personal information (such as name, address, social security number, telephone number, or email address) from individuals under 13 years of age, and specifically instructs children and minors not to submit such information to GTA’s Website without consent of a parent or guardian. If a child or minor provides personal information without the consent of a parent or guardian, the parent or guardian can contact us. We will use all reasonable efforts to delete this information from our files.
Non-Personal Information Collected Automatically
In some cases, we might collect information about you that is not personally identifiable. Examples include the type of Internet browser or computer operating system you are using, the domain name of the Website from which you linked to our site, or your computer’s IP address.
Similar to personal information, we will not sell non-personal information to third parties unless stated at the time of collection. We might share non-personal information with our business partners.
Use of Cookies and Clear GIF images
A cookie is a small file stored on your computer by your Web browser that can contain details about your Web use, such as user preferences or interests. The GTA Web site might use cookies to gather information that helps us personalize your experience on the site and improve advertisements, products, and services. Internet browsers allow you to erase cookies from your computer, block cookies, or receive a notification before cookies are stored. Please refer to your browser documentation to learn more about these functions.
In addition, we may use clear GIF images in our HTML-based emails and Web pages to help us determine which emails have been opened by recipients and which pages have been viewed. This allows us to assess the effectiveness of our communications and marketing campaigns.
Declining Email Offers
We send email promotions or announcements to you only if you have previously given permission for us to do so. Although many customers appreciate receiving notice of promotions and announcements, we recognize that you should have choice. You can unsubscribe from our email list at any time by completing our online unsubscription form. All email offers from GTA tell you how to decline future offers.
Updating the Privacy Policy
The GTA periodically updates its privacy policies. Updated privacy policies supersede and replace any previously posted policies. When we post an updated policy, we will note the effective date of the new policy. If the GTA considers the changes to be significant, or to have material consequences, we will provide a summary of these changes at the top of the policy for 30 days after the effective date.
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