ONE Touch Communications Privacy Policy

Since 1997, customers have counted on ONE Touch to protect the privacy of information we obtain in the normal course of our business of providing telecommunications services. ONE Touch is committed to safeguarding the privacy of our customers.

Customer Privacy is Important to ONE Touch

ONE Touch has established policies to regulate employee access to customer records. Essentially, we access customer accounts, records or reports for authorized business purposes only. ONE Touch informs and educates our employees about their obligation to safeguard customer information and we hold them accountable for their actions. ONE Touch also attempts to inform our customers about any privacy implications of new products and services that we introduce.

What Information is Obtained and How Is It Used?

ONE Touch obtains information about customers that helps us to provide service, and we use that information for business purposes only.

For example, when you call ONE Touch's Customer Care department, we need to know the account name, your name and customer account number. A Customer Care representative refers to your customer record in order to provide better service. It also may be useful for us to review your telephone bill, your calling patterns, and whether you have special needs. In reviewing this information, we can quickly and effectively address your questions or needs while offering you the most effective services to fit the particular needs of business and/or residential customers. For example, the information in our records helps protect customers, employees or property to investigate fraud or harassment. We also want to ensure that information we obtain and use is accurate.

Your monthly invoice from ONE Touch reflects the billing and payment status of your account, the services you use and much more information. If you see any inaccuracy on your ONE Touch bill, please bring it to our attention and we can work to correct the issue.

When you speak with us at ONE Touch, calls may be monitored and recorded by a supervisor for training and other purposes, to make certain that our customers are provided with the most accurate information and with superior customer care.

Providing Information Outside of ONE Touch

ONE Touch will generally notify you and give you the opportunity to "opt out" of when we disclose telephone customer information outside of our company. We generally keep our records of the services you buy and the calls you make private, and customarily will not disclose this information to outside parties without your consent. However, we may release customer information without your involvement if disclosure is required by law or to protect the safety of customers, employees or property. We also have an obligation to assist law enforcement and other government agencies responsible for protecting the public welfare, whether it be an individual or the security interests of the entire nation. If and when we are asked to help, we do so strictly within the law.

Your Have Control over the Disclosure of Certain Information

You can inform us of the telephone listings you want to include in phone directories and in directory assistance. Customers may also choose to have a non-published, or non-listed number, or to exclude your address from any listings.
In areas where Caller ID services are available, customers have the ability to block the display of their phone number and name. A customer's name and telephone number may be transmitted and displayed on a Caller ID device unless the customer has elected to block such information. Please note that Caller ID blocking does not prevent the transmission of your phone number when you dial certain business numbers, including 911, or 800, 888, 877, and 900 numbers.

In Some Instances Disclosure of Information is Required by Law or to Protect the Safety of Customers, Employees or Property:

Your location information, when you dial 911, 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. ONE Touch is required by law to give all competitive local exchange carriers access to its customer databases for purposes of serving their customers, exchanging credit information with other carriers, and to provide listings to directory publishers.
In order to comply with court orders, subpoenas or other legal and regulatory requirements, ONE Touch must disclose necessary information. ONE Touch also will 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, and to assist in repairing network outages.
Where permitted by law, ONE Touch may provide information to third parties where required to provide certain ONE Touch-offered products and services. We may also provide personal identifying information to third parties who perform functions or services on our behalf. When we provide such personal identifying information to third parties to perform such functions or services on our behalf we require that they protect the information consistent with this policy and all legal requirements. We may, where permitted or required by law, provide personal identification information to credit bureaus, provide information and/or sell receivables to collection agencies, or provide information to obtain payment for ONE Touch billed products and services or to enforce or apply our customer agreements. In addition, we may notify a responsible governmental entity if we believe that an emergency involving immediate danger of death or serious physical injury to any person requires or justifies disclosure without delay.

Telephone Account Information Rights

The FCC refers to your telephone account information as Customer Proprietary Network Information or CPNI. Under Federal Law, we have the duty to protect the confidentiality of your CPNI. This information includes the type, technical arrangement, quantity, destination, and amount of use of telecommunications services and related billing for these services. ONE Touch may use this information, without further authorization by you, to offer you services of the type you already purchase from us, and the full range of products and services that may be different from the type of services you currently buy from us. In addition to local telephone services (which includes a full range of call features such as Caller ID, Call Forwarding, voicemail, etc), ONE Touch services include long distance, wireless, and data and Internet services. We may also use or disclose your CPNI for legal or regulatory reasons such as a court order, to investigate fraud, to protect against unlawful use of the network and services and to protect other users. A complete description of ONE Touch's service offerings is available on this Web site at www.ONETouchCom.com. Use of your CPNI information permits ONE Touch to offer you a package of services tailored to fit your specific needs.

ONE Touch's Information Collection and Use

ONE Touch obtains and uses individual customer information for business purposes only. Information about our customers helps to provide ONE Touch services. This information may also be used to protect customers, employees and property against fraud, theft or abuse; to conduct industry or consumer surveys; and to ensure good customer relations. Access to databases containing customer information is limited to individuals who need the information to perform their jobs. These individuals follow stringent guidelines when handling that information.

Customers have opportunities to control how we use their individual information to introduce them to new products and services. For example, ONE Touch will not call customers who have expressed a preference not to be called for marketing purposes. Customers can also have their names removed from direct mail lists that we use.

However, we do use individual customer information internally for our own general marketing and planning purposes -- so that we can, for example, develop and market new products and services that meet the needs of our customers. Ordinarily, such information is aggregated so they do not include individual customer identities. Under certain circumstances, we are required by law to disclose the aggregated information to other companies, but in such cases customer identities are not included.

Disclosure of Individual Customer Information

ONE Touch generally enables customers to control how and if ONE Touch discloses individual information about them to other persons or entities, except as set forth herein, required by law or to protect the safety of customers, employees or property.

If ONE Touch enters into a merger, acquisition, or sale of all or a portion of its assets, in most cases, a customer's personal identifiable information will transfer as part of the transaction. We may, where permitted or required by law, provide personal identification information to credit bureaus, provide information and/or sell receivables to collection agencies, or provide information to obtain payment for ONE Touch billed products and services or to enforce or apply our customer agreements. In addition, we may notify a responsible governmental entity if we believe that an emergency involving immediate danger of death or serious physical injury to any person requires or justifies disclosure without delay.

Should ONE Touch be served with valid legal process for customer information, and we are required by law to release the information, ONE Touch would disclose individual customer information to an outside entity. We may also be required by law to provide billing name and address information to a customer's long distance carrier and other telephone companies to allow them to bill for telecommunications services. (Customers should know that, by law, customers with non-published or unlisted service have the right not to have their billing name and address disclosed when they make a calling card call or accept a collect or third party call. However, if customers restrict disclosure, they will be unable to make calling card calls or accept collect and third party calls.)

ONE Touch is required to provide directory publishers with listings information -- name, address and phone number -- for purposes of publishing and delivering directories. In certain instances, ONE Touch shares customer information with other telephone carriers and with law enforcement to prevent and investigate fraud and other unlawful use of communications services.

Importance of Maintaining Accurate Individual Customer Information

ONE Touch is committed to ensuring that the customer information we obtain and use is accurate. Therefore, it is important to verify that our customer records are correct. Customers who find an error in their ONE Touch bills are encouraged to notify ONE Touch. Our customer care representatives will provide explanations of how to correct any inaccuracies if they occur.

Privacy and Introduction of New ONE Touch Services

Customer privacy is also an important consideration in the planning of new services. ONE Touch will endeavor to inform customers of the privacy implications of these new services.

ONE Touch offers several privacy-enhancing services, including Non-Published numbers, Caller ID, Caller ID With Name, Per Call Blocking, and Anonymous Call Rejection. 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 before and after introducing privacy-sensitive products.

At ONE Touch, we are committed to developing additional communications products and services that fit our customers needs. ONE Touch will address customer needs for voice, video and data services. We will investigate the privacy implications new services may have and work to create safeguards for such services before they are introduced. We will endeavor to inform and educate customers about the effect on privacy the new services may have.

Safeguarding Customer Information

All ONE Touch employees are responsible for safeguarding individual customer communications and information. ONE Touch also requires any vendors and consultants we hire, as well as suppliers and contractors, to respect our customers' individual customer information. They must abide by our privacy guidelines when conducting work for us.

ONE Touch requires its personnel to be aware of and protect the privacy of all forms of customer communications including individual customer records. Employees who fail to follow ONE Touch's privacy principles will face disciplinary action, which can include dismissal.

We are committed to ensuring that information we have about our customers is accurate, secure and confidential. We do not modify or disclose the existence or contents of any communication or transmission, except as required by law or the proper management of our business or network. Employees follow strict guidelines when handing customer information. Access to databases containing customer information is limited to individuals who need it to perform their jobs. Our efforts to safeguard customer information range from the use of locks and physical security measures to sign-on and password control procedures. We also utilize internal auditing techniques to protect against unauthorized use of terminals and entry into our data systems.

Customer records are intended to be reasonably safeguarded from loss, theft, unauthorized disclosure, and accidental destruction. In addition, we seek to maintain a secure environment to protect sensitive, confidential, or proprietary records. It is also our policy to destroy records containing sensitive, confidential, or proprietary information in a secure manner. Hard copy confidential, proprietary, or sensitive documents are made unreadable before disposition or recycling, and electronic media is destroyed using methods intended to prevent access to the information. Employees are advised and trained to report instances of stolen property, missing records or suspicious incidents involving customer records. We encourage employees to be proactive in enforcing ONE Touch's privacy policies.

ONE Touch Compliance with Laws and Public Policy Participation

ONE Touch will continue to carefully monitor customer needs and expectations. We support consumer, government and industry efforts to identify and resolve privacy issues. Telecommunications industry perceptions regarding customer privacy continue to change over time. This privacy policy supersedes and replaces all previously posted privacy policies. ONE Touch has the right to make changes and updates to this privacy policy at any time. ONE Touch will examine and update (as it deems necessary) this privacy policy. Any material changes to this privacy policy will be posted on our web site at www.ONETouchCom.com. Please periodically check our web site for any updates to this privacy policy.