China Telecom (Americas) Corporation
Updated as of: June 2016
Introduction and Overview
Your Consent to Our Collection and Use of Your Personally Identifiable Information
Because the Company is part of a world-wide group of affiliated companies that often combine resources, your consent to our collection and use of your personally identifiable information also includes your consent to the transfer, storage and processing of such information between our offices in the United States and our affiliates abroad as may be necessary in connection with our provision of international services.
Our Collection of Your Personally Identifiable Information and CPNI
Personally Identifiable Information. The primary way that we may collect information about you is by asking you to provide it to us, in connection with registering to use our website, requesting information from us or ordering services from us. In that context, we will collect your name, billing address, telephone number and email address. We may also collect debit or credit card information and/or banking details and other relevant payment information necessary for us to process your order or manage our provision of service to you. Also, if you contact us by phone, email or otherwise, we may retain a record of that communication. We will also maintain records of your visits to our websites, including but not limited to traffic data, location data and other communications data as well as the details of transactions you carry out through our websites and the fulfillment of your orders for our services.
Customer Proprietary Network Information (“CPNI”). In the course of providing to you services that you have ordered from us, we may also collect information that is referred to by the Federal Communications Commission (“FCC”) as “Customer Proprietary Network Information” or “CPNI”. This includes information about the type, quantity, configuration, destination, location and amount of use of the telecommunications services you purchase, how you purchase and use those services and related billing and end user information.
Online Activity Tracking.
Cookies. “Cookies” are text files, which may be encrypted, containing small amounts of information that a server may download to your computer or mobile device when you visit a website, use an application, or access an advertisement or widget on a website. Personally identifiable information is not generated by the cookies, but by your input into website order forms, registration pages, payment pages, other online forms, and your use of the website. When you return to a website, your browser retrieves and sends the information in the cookie to the website’s server. Cookies facilitate efficient navigation on websites, identify and remember individual user personal preferences gleaned from use of a website, authenticate log-in information, and gather aggregated website user information. Some cookies, knowns as “Session Cookies,” store a session ID that is not personally identifiable, but only for a particular browsing session. Such cookies store information about pages you view and allow you to easily navigate from one page to another during the browsing session, but are deleted from your computer when the session is over. Other cookies, known as “Persistent or Tracking Cookies,” retain user preferences for future browsing sessions on a website by the same user. Such cookies assign a unique ID to the user’s browser and are not deleted when the browser is closed.
All of the cookies we may use on our website are deployed to help our websites function. They are essential to ensure that you can effectively navigate our website and access your desired content when you visit our websites. We do not utilize cookies that gather information for ad tracking or monetization purposes. Any cookies that we use to gather information about the content you have viewed collects such information on an aggregated and anonymous basis. The information collected by these cookies cannot track browsing activities on other websites.
Hypertext Links. Our websites may include hypertext links to other websites. We have no control over websites that we do not own or maintain. These other websites may be subject to different privacy policies than ours. You should review the specific privacy policies of such websites to be sure that you understand how they collect, use and share your information and so that you can adjust your usage accordingly. We expressly disclaim any and all responsibility or liability for the privacy policies or practices of other websites that may be accessed via hyptertext links from our websites.
Our Use of Your Personal Information
Use by the Company. We are committed to protecting your privacy. Consequently, your personally identifiable information is collected, processed, stored and disposed of in accordance with applicable data protection and privacy laws. Specifically, we process your personally identifiable information solely to:
- provide access to our websites;
- process service order(s);
- provide services, including to process billing and payment information;
- administer services;
- analyze the use of our websites and services on a personalized or aggregated basis to gather broad demographic information, interests, and behavior so that we may better tailor our websites and services in accordance with customer preferences;
- process IP addresses to help diagnose problems with our servers and administer our websites;
- inform customers of any new promotions and services offered, improve our level of service and provide notifications regarding service changes or outages or in order to carry out market research; and
- investigate any complaints or other inquiries customers may submit to us.
We would like to keep you up to date with details of our services using the information that you have supplied. We will do this in accordance with applicable privacy laws and FCC policies, and in accordance with any direct marketing permissions which were given by you when we collected information from you.
Sharing with Others
Other than as mentioned above, we may disclose personally identifiable information and account information in special cases when legal interests are at stake. For example, we may disclose such information as is necessary to identify, contact, or bring legal action against someone who may be violating a user agreement or may be causing injury to or interference with us, you, or anyone else that could be harmed by such activities. We may disclose personally identifiable information as necessary to collect payment for the services we provide. We also may disclose such information as is required by government or law enforcement officials. We can, and you hereby authorize us to, disclose any information to law enforcement or other parties that we, in our sole discretion, believe is required or appropriate to comply with the law.
We may share non-personal, non-individual information in aggregate form with selected third parties. Other than as set forth herein, we do not sell or disseminate personally identifiable information to third parties without your consent.
Our Retention of Your Personal Information
The length of time we keep your information for can vary depending upon the way in which we use the information. Unless there is a specific legal requirement to keep your information, we will not keep it for longer than we believe is reasonably necessary for the purposes for which the data was collected.
Our websites do not target and are not intended for use by children under the age of 13, and we abide by the United States’ Children’s Online Privacy Protection Act (CORPA) and other applicable laws relating to the use of children’s data. We do not knowingly collect or maintain personally identifiable information from children under the age of 13.
Data Protection and Security
We have implemented reasonable technical and organizational measures to secure your personally identifiable information from accidental loss and from unauthorized access, use, alteration or disclosure. Our websites have security measures in place to protect against the loss, misuse and alteration of information under our control. However, the internet is an open system, and we cannot guarantee that unauthorized third parties will not be able to defeat the security measures we have in place, or that they will not use your personally identifiable information for improper purposes.
Certain information may be transmitted to you by electronic mail. Although it may be illegal to intercept or disclose such messages, the transmissions are not secured.
Customer Choice, Controls and Changes
You may request a copy of the personally identifiable information we hold about you, such as contact information, banking details and marketing preferences, and you may review, correct, update, change or delete this information at any time by submitting a request to firstname.lastname@example.org. Please note that in certain circumstances we may withhold access to your information where we are required to do so by applicable law or order, or have the right to do so under current data protection legislation.
China Telecom (Americas) Corporation
607 Herndon Parkway, Suite 201
Herndon, VA 20170
Changes to the Policy