PRIVACY POLICY

360 Communications, Inc. Privacy Policy and Customer California Privacy Rights

Effective as of April 28th, 2022

360 Communications, Inc.  (“360 Communications”) knows Customers care about how their personally identifiable information (“Personal Information”) is used and shared, and 360 Communications takes Customers’ privacy seriously. Please read the following to learn more about 360 Communications’s Privacy Policy. By using the Service (as defined in the Customer’s Terms of Service Agreement (“TSA”) or Premium Service Agreement ( “PSA” or collectively “Service Agreements”)) or accessing 360 Communications’s website (“Site”) in any manner, Customer acknowledges that Customer accepts the practices and policies outlined in this Privacy Policy, and Customer hereby consents that 360 Communications will collect, use, and share Customer’s Personal Information in the following ways in order to deliver the services requested by Customer. Remember that Customer’s use of the Service is at all times subject to Customer’s TSA or PSA, which incorporates this Privacy Policy by reference.  Any capitalized terms not defined in this Privacy Policy will have the same meaning as defined in Customer’s TSA or PSA, and Website Terms of Use. (Can be found at http://www.threesixtycomm.net/legal-and-regulatory)

Your California Privacy Rights

Generally, California residents are entitled by law to ask 360 Communications for free information twice a year identifying the categories of Personal Information which 360 Communications shares with its Affiliates and/or other third parties for their marketing purposes the preceding year, and to provide contact information for such Affiliates and/or third parties unless 360 Communications meets certain exceptions in the law. This Privacy Policy qualifies for the exception to those requirements. Therefore, if Customer resides in California and Customer has an established business relationship with 360 Communications, Customer may request information about 360 Communications’s opt-out and out-in policies of sharing Customer Personal Information with other companies (including our Affiliates) for their marketing purposes. Please send Customer’s written request via email or postal mail following the instructions below. 360 Communications will not accept requests via the telephone or facsimile. 360 Communications will not respond to requests that are not labeled or sent properly, or do not have complete information. 

  • For all requests, include Customer’s full name, street address, city, state and zip code. 
  • In an email request, Customer must state “Re: Your California Privacy Rights” in the subject line and send Customer email to support@360broadband.net .
  • In a postal request, Customer must send a letter or post card to: 360 Communications, Inc. PO BOX 1663 Durant, OK 74702 Attention: Your California Privacy Rights

General Information

360 Communications’s Site and Services are designed and targeted to U.S. audiences and are governed by and operated in accordance with the laws of the U.S. If Customer is not a U.S. citizen or do not reside in the U.S., Customer voluntarily consents to the collection, transfer, use, disclosure and retention of Customer Personal Information (as defined below) in the U.S. Customer also agrees to waive any claims that may arise under Customer’s own national laws.

When Customer uses the Service, the Personal Information Customer sends and receives is transmitted over a wireless network, and may be subject to interception by unauthorized third parties who seek to do you harm. While it is 360 Communications’s objective to take reasonable measures to reduce the risk that unauthorized third parties will be able to intercept the information Customer sends and receives through the Service, 360 Communications cannot and does not make any guarantee that transmissions over the Internet are 100% secure or error-free.

360 Communications recommends that Customers use caution when sending any Personal Information over the Internet and use encryption technology whenever possible, such as websites that have the “https” designation in the website’s address bar and show a padlock icon in the browser’s window.

360 Communications does not knowingly collect, solicit or use Personal Information from anyone under the age of 13. If Customer is under age 13, please do not attempt to register for the Services or send any Personal Information about yourself to 360 Communications. If 360 Communications learns that 360 Communications has collected Personal Information from a child under age 13, 360 Communications will delete that information as quickly as possible to the extent technically feasible. If Customer believes that its child under age 13 may have provided 360 Communications Personal Information, please contact 360 Communications at support@360broadband.net .  

What types of information does this Privacy Policy cover?

360 Communications collects various types of information about Customers and Customers’ use of the Service via the 360 Communications website, Help Desk and call centers, postal mail, remote kiosks, the 360 Communications Facebook Page or other social network platforms or by other means, generally classified as Personal Information and Non-Personal Information. Generally, 360 Communications gathers and uses Personal Information internally in connection with providing the Service to Customer, including to personalize, evaluate and improve the Service and 360 Communications’s ability to provide the Service to Customer, to contact Customer, to respond to and fulfill Customer requests regarding the Service, and to analyze how Customer uses the Service. 360 Communications may share Customer’s Personal Information with its Affiliates and with other third parties as described below:

What Information does 360 Communications collect and how does 360 Communications use this Information?

Personal Information

Personal Information is the information Customer provides to 360 Communications voluntarily or passively through Customer use of the Service and/or website, and which is directly associated with or reasonably linked to a specific person, computer or device. For example, through the registration process, when the equipment to provide the Service is installed, maintained or upgraded at Customer’s premises, when Customer contacts 360 Communications regarding the Service, and through Customer account settings, 360 Communications collects Personal Information such as Customer name, email address, phone number, billing address and billing information (such as credit card account number or other financial account information), service address, and the nature of any of Customer devices or other property making use of the Service. Personal Information also includes Customer proprietary network information (“CPNI”) which is collected and used to provide VoIP services.  CPNI includes any information that relates to the quantity, technical configuration, type, destination, location, and amount of use of our VoIP service, such as call detail, logs, and specifics regarding your VoIP account.

Customer may be required to provide certain Personal Information to 360 Communications in order to register with 360 Communications, to assist 360 Communications in improving Customer’s Service or troubleshooting problems Customer is experiencing with the Service, Customer computer or device, or otherwise to improve the quality of the Service. 360 Communications will communicate with Customer if Customer has provided 360 Communications the means to do so. For example, if Customer has given 360 Communications Customer’s email address or phone number, 360 Communications will email or call Customer about Customer use of the Service or product improvements or upgrades, and other transactional information about Customer Service. 360 Communications may also combine Customer Personal Information with additional Personal Information obtained from 360 Communications Facebook Pages or other social network platforms, its Affiliates, its Operational Service Providers (third party owned companies that provide or perform services on 360 Communications’s behalf, to help serve Customer better and to perform functions in order to support 360 Communications businesses and operations), or other companies, such as credit bureaus, background check firms, and marketing research companies. Some forms of Non-Personal Information as described below will be classified as Personal Information if required by applicable law or when such information is directly associated with or reasonably linked to a specific person, computer or device, or is combined with other forms of Personal Information.

Non-Personal Information

Website Information, Use of Cookies and other Similar Tracking Technology Used for Standard Business Operations

When you visit 360 Communications’s website, 360 Communications will collect various types of Non-Personal Information, such as information on 360 Communications server logs from Customer’s browser or device, which may include Customer IP address, unique device identifier, “cookie” information, the type of browser and/or device you’re using to access the Service, and the page or feature Customer requested. (IP Address and device identifiers are traditionally classified as Non-Personal Information, unless 360 Communications is required to do so otherwise under applicable law.) “Cookies” and “web beacons” are text file identifiers 360 Communications transfers to Customer’s browser or device that allow 360 Communications to recognize Customer’s browser or device and tell 360 Communications how and when pages and features on the 360 Communications website are visited, by how many people, and other activity on the website. Customer can change the preferences on Customer’s browser or device to prevent or limit Customer’s device’s acceptance of cookies, web beacons or other similar technology, but this may prevent Customer from taking advantage of some of the features on the 360 Communications website, or accessing certain functions and conveniences. If Customer clicks on a link to a third party website or service, such third party may also transmit cookies to Customer. Again, this Privacy Policy does not cover the use of cookies or other such tracking technology by any third parties, and 360 Communications is not responsible for their privacy policies and practices. 360 Communications also uses Personal Information and Non-Personal Information to enhance the 360 Communications website and 360 Communications Service offerings. For example, such information can tell 360 Communications how often visitors use a particular feature of the 360 Communications website and which products and services are most interesting to current and potential Customers, and 360 Communications can use that knowledge to make the website useful and interesting to as many users as possible and to enhance and refine 360 Communications’s Service offerings. 360 Communications will continue to conduct analytics on 360 Communications website performance; Customer may not opt-out of this use of cookies or other Personal Information or Non-Personal Information.

Technology is improving every day and to improve 360 Communications’s Services’ operations and functions, 360 Communications may introduce new technologies and monitoring techniques without advance notice or consent from Customer, unless required by law. 360 Communications may also use third party providers to conduct such internal analyses.

Network Information Used for Standard Business Operations

360 Communications also collects Network Information, information about Customer access to, and use of, the 360 Communications Network, which may or may not be directly associated with or reasonably linked to a specific person, computer or device. For example, 360 Communications may collect information about the performance of the Provider Equipment installed on Customer property or at Customer premises, when Customer is using the Service, the various devices Customer is using to access the Service, the amount of data Customer is transmitting and receiving, the content of the data Customer are transmitting and receiving, the websites Customer is visiting, and any other information that is transmitted over the 360 Communications Network. 360 Communications may also aggregate Network Information from multiple customers and 360 Communications will share such aggregated Non-Personal information about the overall performance of the 360 Communications Service and the 360 Communications Network with our Affiliates and other third parties. Aggregated information does not identify a specific individual, computer or device. We use Network Information to monitor and enhance the performance of the 360 Communications Network. 360 Communications will not monitor the content of the websites viewed or email communications as part of 360 Communications’s standard network management.

Generally, 360 Communications will only monitor and preserve the following Network Information:

  • When Customer is using the Service;
  • How Customer is using the Service, such as monitoring traffic patterns regarding websites visited, amount of data being sent or received, or other activity;
  • The amount of data Customer is transmitting and receiving through the Service; and
  • General information regarding the performance of the Provider Equipment installed on Customer’s property or at Customer’s premises, and its interaction with the rest of 360 Communications’s Network.

However, 360 Communications reserves the right to, and may, monitor, access, review and preserve any Network Information and/or content in the following situations:

  • In response to an inquiry from Customer or another Authorized User on Customer’s account regarding Customer or their use of the Service or problems Customer or they are experiencing using the Service;
  • If 360 Communications has reason to believe Customer is using the Service in violation of Customer’s TSA or PSA or any applicable statutes, rules, ordinances or regulations;
  • If 360 Communications has reason to believe Customer use of the Service is negatively affecting other Customers; or
  • When 360 Communications is required by law or legal process to do so, or when 360 Communications a good faith belief that 360 Communications is required by law or legal process to do so.

      

How is Personal Information used for marketing and advertising purposes?

360 Communications will use Personal Information to send Customer marketing and advertising messages related to 360 Communications’s Service and website using Customer’s email address, postal address, or telephone number (for voice, texts, and pre-recorded calls). 360 Communications may deliver a marketing or advertising message based on Customer visits to 360 Communications website, which will be general advertising or “Contextual Advertising,” which is advertising based on the subject matter or the content of the specific website page or subject matter. 360 Communications may also send Customer “First Party Advertising,” which is advertising that is customized or personalized based on a history of Customer’s use of our Services (possibly combined with information from our Facebook fan page or other social network platforms). First Party Advertising is based solely on a combination of information 360 Communications collects from Customer – not from Customer’s visits to other websites across the Internet. Customer may opt-out of First Party Advertising but not Contextual Advertising. No Personal Information is used to deliver Contextual Advertising; it automatically will appear based on the content or webpage Customer is viewing. And Customer may continue to receive general advertising if Customer opts-out of First Party Advertising, it will not be customized or personalized for Customer. 360 Communications does not provide third party “Network Advertising,” which is advertising based on Customer’s overall Internet usage across different third party websites or online services. Multiple third party websites and online services are involved in this tailored or personalized advertising process, in essence a “network” of advertising providers. Because 360 Communications does not provide network ads, 360 Communications does not recognize the “Do Not Track” settings on various Internet browsers. 360 Communications does not engage or allow third parties to track you across the Internet and across time for advertising purposes.

The 360 Communications Site and/or Facebook Pages (or other social networking platforms) may contain a variety of content and functionality and may provide links to other third party websites or online services. Despite such links, this Privacy Policy applies only to 360 Communications and our Affiliates. The presence of a link does not constitute or imply 360 Communications’s endorsement, recommendation, or sponsorship of the content, goods, services, business or privacy practices on such websites or online services. 360 Communications encourages Customers to be aware and informed when Customers leave 360 Communications’s website and 360 Communications’s Facebook Pages, or any other social networking platforms.

Customer’s Personal Information will only be disclosed to third parties (including 360 Communications’s Affiliates) as listed in this Privacy Policy, if 360 Communications has received your consent at the time 360 Communications will collect your Personal Information or prior to the disclosure of any Personal Information. 360 Communications reserves the right to fully use, disclose and process any Non-Personal Information collected from Customer in any manner as well as any information Customer makes public via 360 Communications Services or website. 360 Communications will not rent, sell or disclose Personal Information to anyone not related to 360 Communications for marketing or promotional purposes, unless in connection with a potential or actual sale, merger or a corporate restructuring by or of 360 Communications. (See “For Business Transfers” below for more information.)

360 Communications will share Customer Personal Information with its Affiliates and with other third parties as described in this section for standard business operations :

  • To Our Affiliates. 360 Communications may rely on various Affiliates in order to provide the Service to Customers. These are companies that are related to 360 Communications by common ownership or control. 360 Communications may share Personal Information and Non-Personal Information with any of its Affiliates for business, operational, and 360 Communications’s own (First Party) promotional and/or marketing and advertising purposes.   
  • To Operational Service Providers: 360 Communications and its Affiliates contract with other companies and people to perform tasks or services on 360 Communications’s behalf and need to share Customer Personal Information to provide products or services to Customers. For example, 360 Communications may use a payment processing company to receive and process Customer’s ACH or credit card transactions for 360 Communications, or 360 Communications may contract with third parties to assist 360 Communications in optimizing the 360 Communications Network. Unless 360 Communications tells Customer differently, 360 Communications does not grant its Operational Service Providers any right to use the Personal Information 360 Communications shares with them beyond what is necessary to assist 360 Communications.
  • For Business Transfers/Restructuring: 360 Communications may choose to buy or sell assets, or 360 Communications may sell assets or be sold. In these types of transactions, Customer Personal Information is typically one of the business assets that would be disclosed and transferred. Also, if 360 Communications (or 360 Communications’s assets) are acquired, or 360 Communications goes out of business, enter bankruptcy, or go through some other change of control, including restructuring, re-organization or financing arrangements, Personal Information could be one of the assets disclosed, transferred to or acquired by a third party.
  • For Protection of 360 Communications, and Our Affiliates, Employees, Operational Service Providers, Users and Customers and Public Safety: 360 Communications reserves the right to access, read, preserve, and disclose any Personal Information 360 Communications has access to if 360 Communications believes doing so will implement and/or enforce the TSA or PSA, Website Terms of Use Agreement, Privacy Policy or any legal document; protect the 360 Communications Network(s), website(s), and company assets; protect the interests, rights, property, and/or safety of 360 Communications or our Affiliates, employees and officers/directors, Operational Service Providers, Users and Customers, agents, third party licensors or suppliers, or the general public.
  • When Required by Law or in Response to Legal Process: 360 Communications reserves the right to access, read, preserve, and disclose any Personal Information to which 360 Communications has access if 360 Communications is required by law or legal process to do so, or if 360 Communications has a good faith belief that 360 Communications is required by law or legal process to do so.

Is Customer Personal Information secure?

360 Communications endeavors to protect the privacy of Customer’s account and other Personal Information 360 Communications by using reasonable administrative, technical and physical security measures. However, 360 Communications cannot and do not guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of Personal Information at any time. Customer’s account is protected by a password for Customer privacy and security. It is Customer’s responsibility to prevent unauthorized access to Customer’s account and Personal Information by selecting and protecting Customer password and/or other sign-on mechanism appropriately and limiting access to Customer computer, tablet or device and browser by signing off after Customer has finished accessing Customer’s account. Customer is required to notify us immediately if Customer’s password or account has been disclosed to a person whose name does not appear on Customer’s account, even if you have allowed such disclosure. Customer understands, acknowledges and agrees that Customer is solely responsible for any use of 360 Communications Services via Customer’s username and password.

Additionally, if Customer contacts 360 Communications, 360 Communications will ask Customer for verification of Customer’s identification and account. 360 Communications will not send an email or text, nor should Customer respond to any email or text communications asking for any sensitive or confidential Personal Information, such as social security number, bank account or credit card account number, or a driver’s license number. If Customer receives an email or text requesting any such information from 360 Communications or someone that claims they are with 360 Communications or Our Affiliates please contact our Privacy Administrator immediately: privacy@360broadband.net For 360 Communications’s IT Support Services as detailed in our TSA or PSA, the code that allows 360 Communications to access Customer’s computer desktop to help your resolve technical problems is limited only for that specific session. 360 Communications is not able to access Customer’s Computer without Customer’s knowledge, affirmative consent and involvement.

What Personal Information can Customers access, modify and/or delete?

Generally, Customer may access the following Personal Information in Customer’s account:

•          Full name

•          Username and password

•          Email address

•          Telephone number; and

•          Billing and Service address

•          Account and billing information

By contacting 360 Communications at support@360broadband.net , or through any online access portal and/or via telephone, 360 Communications may enable Customers to view, access and modify Customer account settings, and in some cases, edit or delete the Personal Information listed above. For example, 360 Communications may retain historic email, billing and/or Service addresses for security and verification purposes and Customers may not delete such information even after the subscription expires or terminates. Current Customers may not delete any Personal Information because such information is necessary to provide and bill for the Service; Customers may only update or modify Personal Information. When Customer updates Personal Information, however, 360 Communications may maintain a copy of the unrevised information in 360 Communications’s records for internal security reasons and recordkeeping. Some information may remain in 360 Communications’s records after it is modified, amended or deleted by Customer or 360 Communications. 360 Communications may use any aggregated data derived from or incorporating Customer’s Personal Information after Customer updates or deletes it, but not in a manner that would identify Customer personally. 360 Communications may also maintain Personal Information regarding Customer and Customer’s use of the Service after Customer is no longer a 360 Communications Customer as required by 360 Communications’s business practices, by law, and/or tax reporting purposes. The information Customer can view, update, and delete may also change. If Customer has any questions about viewing or updating information 360 Communications has on file about Customer, please contact 360 Communications at support@360broadband.net .

What third party disclosure choices do Customers have?

Customer can always choose not to disclose Personal Information to 360 Communications; however, certain Personal Information is necessary for 360 Communications to provide the Service to Customer and is part of 360 Communications’s standard business operations. If you are a Customer of 360 Communications, you have already provided your written consent to 360 Communications for the disclosure of the information pertaining to this subscription. Customer may opt out of sharing Personal Information with our Affiliates only for marketing or advertising purposes, but not for business or operational purposes. Customer may opt out of email marketing and advertising from 360 Communications or its Affiliates using the “Unsubscribe” mechanism in each email. Before 360 Communications sends Customer a text for any reason, or sends Customer a pre-recorded call that contains advertising or marketing information, 360 Communications will secure Customer’s prior written express consent, which can be given via a voice recording, email, text message, postal mail, or telephone key press. Non-telemarketing pre-recorded calls do not require Customer’s prior express consent in writing, unless they are sent to a wireless device. Customer understands, acknowledges and agrees that such texts and pre-recorded telemarketing calls may be sent using an autodialer and are not conditioned on your purchase of the Service. Customer may opt out of receiving text messages any time by replying “STOP” or “UNSUBSCRIBE” to the text message. Customer may opt out of receiving pre-recorded calls by the opt-out instructions in the call. Customer can also request to be added to 360 Communications’s company-specific Do Not Call list to opt-out of advertising and marketing calls of all types. However, Customer will continue to receive calls related to debt-collection and Customer’s current Service. Customer may also opt-out of First Party Advertising, but not Contextual Advertising, as detailed in the “Use of Personal Information for Marketing or Advertising Purposes” section above. Customer may not opt out of 360 Communications’s use of cookies or other similar technology, or use of Customer’s Personal Information and Non-Personal Information for 360 Communications’s internal analytics used to monitor activity on 360 Communications’s website, measure 360 Communications’s Service performance, or to operate and protect the 360 Communications Network.

Will this Privacy Policy ever change?

Yes, 360 Communications is constantly working to improve the Service, so 360 Communications will need to update this Privacy Policy from time to time as 360 Communications’s business practices change and service offerings increase, and/or there are changes in local, state or federal laws. Additionally, 360 Communications will also make stylistic, organizational and/or grammatical changes to present 360 Communications privacy practices in a user friendly easy to read manner. 360 Communications will alert Customers to any such changes by placing a notice on www.360broadband.net with the effective date of the revised Privacy Policy, and/or by sending Customers an email, or by some other means to the extent required by law. Please note that if Customers have not provided 360 Communications with Customer’s email address or Customer has not updated Customer contact information, those legal notices will still govern Customer use of the Service, and Customer is still responsible for reading and understanding all notices posted on 360 Communications’s website. Customer’s continued use of the Service or website after notice of any changes have been provided will indicate Customer’s acceptance of such changes, except where further steps are required by applicable law.

Use of Customer’s Personal Information is primarily governed by the Privacy Policy in effect at the time Customer subscribed to the Service or visited the 360 Communications website. If 360 Communications elects to use or to disclose Personal Information or Customer information pertaining to the subscription l in a manner that is materially different than that stated in the Privacy Policy in effect at the time you subscribed to the Service or visited the 360 Communications Site, 360 Communications will provide Customer with an opportunity to consent to such use or disclosure. Depending on the circumstances, that consent may include an opt-out.

What if you have questions or comments about this Privacy Policy?

If you have any questions or concerns regarding 360 Communications’s privacy practices and policies, please contact 360 Communications at privacy@360broadband.net  

© Copyright 2022, 360 Communications Internet, Inc.

– All Rights Reserved.

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