Why am I receiving this policy from Insight?
What kind of information does this policy apply to?
For what purposes may Insight collect personally identifiable information and CPNI?
What kind of personally identifiable information and CPNI does Insight collect?
What kind of information does Insight collect if I use interactive or transactional services?
II. Use of Personally Identifiable Information and CPNI
III. Disclosure of Information
Under what circumstances may Insight disclose personally identifiable information to others?
When may Insight disclose personal information and CPNI to others in connection with phone service?
When does Insight disclose information to Government Entities or others pursuant to legal process?
How does Insight protect personally identifiable information?
How long does Insight maintain personally identifiable information?
IV. Customer Access and Choice
How can I see my personally identifiable information or CPNI and correct it, if necessary?
When will I receive notices or information about changes to this policy?
What can I do if I have questions or concerns about my privacy rights?
Why am I receiving this policy from Insight?
As a customer receiving cable service or other services provided by Insight, you are entitled under Section 631 of the federal Cable Communications Policy Act of 1984, as amended (the "Cable Act"), to be informed of our practices with respect to the collection and use of your information. Insight takes very seriously its obligations relating to customer privacy and this policy is intended to notify you of our practices. In this policy, the terms "Insight," "we," "us," or "our" refer to Insight Communications Company, Inc. or its affiliated operating company providing the applicable service. The term "you" refers to you as a customer to our cable service and/or other services. This privacy policy describes in particular:
- the limitations imposed by the Cable Act upon cable operators with respect to the collection and disclosure of personally identifiable information about customers;
- the types of personally identifiable information we collect;
- the manner in which we use your personally identifiable information;
- circumstances under which we may disclose personally identifiable information and to whom;
- the period during which we maintain personally identifiable information;
- the times and place at which you may have access to your personally identifiable information; and
- your rights under the Cable Act concerning personally identifiable information and its collection and disclosure.
Personally identifiable information is information that identifies a particular person. Aggregated data that does not identify a particular person or persons is not considered personally identifiable information.
In addition to our obligations relating to personally identifiable information under the Cable Act, we are required under the federal Telecommunications Act of 1996, as amended (the "Telecommunications Act"), to adhere to certain additional privacy practices with respect to certain information derived from our provision of phone services:
- information about the quantity, technical configuration, type, destination, location, and amount of your use of the phone services; and
- information contained on your telephone bill concerning the phone services you receive.
That phone information, when matched to your name, address, and telephone number is known as customer proprietary network information, or CPNI. This policy also describes what CPNI we obtain, how we protect it, and how it may be used. Our obligations with respect to CPNI apply to our provision of Insight phone services.
I. Collection of Information
What kind of information does this policy apply to?
The Cable Act applies to personally identifiable information that you have furnished to Insight, or that Insight has collected using the cable system, in connection with the provision of cable service or other services. The Telecommunications Act applies to CPNI related to our regulated phone services. This policy applies to our cable television services, our high-speed Internet services, and our phone services as provided for by applicable law and except as otherwise noted.
For what purposes may Insight collect personally identifiable information and CPNI?
The Cable Act authorizes Insight as a cable operator to use the cable system to collect personally identifiable information concerning any customer for the following purposes:
- in order to obtain information necessary to render cable service or other services to customers; and
- to detect unauthorized reception of cable communications.
The Cable Act prohibits us from using the cable system to collect personally identifiable information concerning any customer for any purposes other than those listed above without the customer's prior written or electronic consent.
The Telecommunications Act authorizes us to use, disclose, or permit access to individually identifiable CPNI in our provision of the following services, and we collect information for the provision of the services:
- the telecommunications service from which this information is derived; or
- services necessary to, or used in, the provision of these services, including the publishing of directories.
The Telecommunications Act prohibits us from using CPNI for any purposes other than those listed above except as permitted or required by law or with your approval.
What kind of personally identifiable information and CPNI does Insight collect?
We collect information from you at several different points when you initiate and use our services. Some of this information is personally identifiable information, but much of it is not. We collect certain personally identifiable information that our customers furnish to us in connection with the provision of cable service or other services. In order to provide reliable, high quality service to you, we keep regular business records containing information about you that may constitute personally identifiable information. These records may include the following information: your name; service address; billing address; e-mail address; telephone number; driver's license number; social security number; bank account number; credit card number; and other similar account information.
With respect to phone services, examples of CPNI include information typically available from telephone-related details on your monthly bill, such as: location of service; technical configuration of service; type of service; quantity of service; amount of use of service; calling patterns; and other information contained on your bill for local and long distance services. CPNI does not include your name, address, and telephone number, which is not subject to the protections applicable to CPNI. However, that information is subject to certain protections as described below under the heading "To whom may Insight disclose personally identifiable information?"
We also collect and maintain certain other information about your account. For example, this information may include: billing, payment, and deposit history; additional service information; customer correspondence and communications records; maintenance and complaint information; records indicating the number of television sets, set-top boxes, modems, or telephones connected to our cable system; and additional information about the service options you have chosen.
Some of our services permit you to establish secondary accounts, and if you do so we may collect similar information in order to establish and service the secondary accounts. During the initial provisioning of our services, and during any subsequent changes or updates to our services, Insight 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, and customization settings and preferences. In addition, if you rent your residence, we may have a record of whether landlord permission was required prior to installing our cable facilities as well as your landlord's name and address.
What kind of information does Insight collect if I use interactive or transactional services?
When you use our interactive or other transactional services, such as video on demand, our systems may automatically collect certain information about your use of these services. Most of this information is not personally identifiable information and it is simply used, to carry out a particular request you make using your remote control, set-top box, or other equipment. This may include information required to change your television channel, review listings in an electronic program guide, pause or fast forward through certain on demand programs, or invoke a calling feature, among other things. It may also include other information such as the time you actually use our services and the use of other features of our services, and which menus and menu screens are used most often and the time spent using them. In order to carry out a particular request you make to watch a pay-per-view program or purchase a product, service, or feature, our system may collect certain personally identifiable information. This information typically consists of account and billing-related information such as the pay-per-view programs or other products, services, or features ordered so that you may be properly billed for them.
Some of our systems may collect limited anonymous, aggregate information using set-top boxes and other equipment. We use this aggregate information to determine which programs are most popular, how many people watch a program to its conclusion, and whether people are watching commercials. As described below under "Use of Personally Identifiable Information and CPNI" we may provide certain anonymous, aggregate information to third parties, such as audience measurement firms, who may combine it with other aggregated demographic information (such as census records) to provide us with audience analysis information. We use this information to improve our cable television service and other services and make programming and advertising more relevant to our subscribers. We may also use this information to distribute relevant programming and advertising to you without disclosing personally identifiable information about you to programmers or advertisers. Some of these programs or advertisements may invite your participation, which you can accept or decline by using your program guide commands or by following any special instructions on your video screen.
II. Use of Personally Identifiable Information and CPNI
We collect, maintain, and use personally identifiable information and CPNI as permitted by the Cable Act, the Telecommunications Act and other applicable laws. We use this information primarily to conduct business activities related to providing you with our cable service and other services, and to help us detect theft of service.
We currently do not use CPNI to market or offer products or services to customers. We will notify you if we modify or change this policy. Any action that you take to deny or restrict approval to use your CPNI will not affect our provision to you, now or in the future, of any service to which you subscribe.
Generally speaking, we may use other personally identifiable information in connection with: billing and invoicing; administration; surveys; collection of fees and charges; marketing; service delivery and customization; maintenance and operations; technical support; hardware and software upgrades; and fraud prevention. More specifically, we may use personally identifiable information to: install, configure, operate, provide, support, and maintain our cable service and other services; confirm you are receiving the level(s) of service requested and are properly billed; identify you when changes are made to your account or services; make you aware of new products or services that may be of interest to you; understand the use of, and identify improvements to, our services; detect unauthorized or unlawful reception, use, or abuse of our services; determine whether there are violations of any applicable policies and terms of service; manage the network supporting our services; configure cable service and other service-related devices; and comply with law.
If you are moving (porting) your telephone number from another carrier to us, you may be asked during a telephone call with one of our representatives for your oral consent to our use of your CPNI with your current carrier for the purpose of porting your telephone number to us. If you provide your oral consent for us to do so, we may use your CPNI only for the duration of the transition of service from your previous carrier to us.
Also, the Telecommunications Act permits us to use CPNI obtained from our customers, either directly or indirectly, with or without their consent, to: (i) initiate, render, bill, and collect for telecommunications 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) provide any inbound telemarketing, referral, or administrative services to you for the duration of the call, if you initiated the call and you approve of the use of this information to provide these services; and (iv) to provide call location information concerning the user of a commercial mobile phone service. The circumstances under which we may disclose CPNI to third parties are discussed in Section III, below.
We transmit, and may collect and store for a period of time, personally identifiable and non-personally identifiable information about you when you use our high-speed Internet and/or phone services, as applicable, to: send and receive e-mail, video mail, and instant messages; transfer and share files; make files accessible; visit websites; place or receive calls; leave and receive voice mail messages; establish custom settings or preferences; communicate with us for support; or otherwise use the services and their features.
Our transmission, collection, and storage of this information is necessary to render the services. In certain situations, third-party service providers may transmit, collect, and store this information on our behalf to provide features of our services. These third parties are not permitted to use your personally identifiable information except for the purpose of providing these features.
We may also combine personally identifiable information, which we collect as described in this policy as part of our regular business records, with personally identifiable information obtained from third parties for the purpose of creating an enhanced database or business records. We may use this database and these business records in marketing and other activities related to our cable service and other services. We also maintain records of research concerning subscriber satisfaction and viewing habits, which are obtained from customer interviews and questionnaires.
III. Disclosure of Information
Under what circumstances may Insight disclose personally identifiable information to others?
We consider the personally identifiable information contained in our business records to be confidential. The Cable Act authorizes us as a cable operator to disclose personally identifiable information concerning any customer if the disclosure is:
- necessary to render, or conduct a legitimate business activity related to, the cable service or other services provided to the subscriber;
- required by law or legal process (described below under "When does Insight disclose information to Government Entities or others pursuant to legal process"); or
- of the names and addresses of subscribers for "mailing list" or other purposes (subject to each subscriber's right to prohibit or limit this disclosure as described herein).
The Cable Act prohibits us from disclosing personally identifiable information concerning any subscriber for any purposes other than those listed above without the subscriber's prior written or electronic consent.
As noted in the first bullet above, we may disclose personally identifiable information as provided for in the Cable Act when it is necessary to render, or conduct a legitimate business activity related to, the cable service or other services we provide to you. These kinds of disclosures typically involve billing and collections, administration, surveys, marketing, service delivery and customization, maintenance and operations, and fraud prevention, for example. We may also sometimes disclose personally identifiable information about you to our affiliates or to others who work for us, to outside auditors, professional advisors, service providers and vendors, potential business merger, acquisition, or sale partners, and regulators, when the disclosure is necessary to render, or conduct a legitimate business activity related to, the cable service or other services we provide to you. We may also collect, use, and disclose information about you in non-personally identifiable or aggregate formats, such as ratings surveys and service usage and other statistical reports, which do not personally identify you, your particular viewing habits, or the nature of any transaction you have made over the cable system. The frequency of any disclosure of personally identifiable information varies in accordance with our business needs and activities.
As noted in the third bullet above, the Cable Act authorizes us as a cable operator to disclose limited personally identifiable information to others, such as charities, marketing organizations, or other businesses, for cable or non-cable "mailing list" or other purposes. From time to time we may disclose your name and address for these purposes. However, you have the right to prohibit or limit this kind of disclosure by notifying us in writing at Insight's local office. Any "mailing list" and related disclosures that we may make are limited by the Cable Act to disclosures of subscriber names and addresses and may not reveal, directly or indirectly, (i) the extent of any viewing or other use by the subscriber of a cable service or other service provided by us; or (ii) the nature of any transaction made by the subscriber over our cable system.
If we enter into a business transaction, such as a merger, acquisition, or sale of all or a portion of our assets, customers' personally identifiable information may be one of the items transferred as part of the transaction.
Finally, we may use or disclose personally identifiable information about you without your consent to protect our customers, employees, or property, in emergency situations, to enforce our rights under our terms of service and policies, in court or elsewhere, and as otherwise permitted by law.
When may Insight disclose personal information and CPNI to others in connection with phone service?
We may disclose to others personally identifiable information in connection with features and services such as Caller ID, 911/E911, and directory services as follows:
- We may transmit your name and/or telephone number to be displayed on a Caller ID device unless you have elected to block such information. Please note that Caller ID blocking may not prevent the display of your name and/or telephone number when you dial certain business or emergency numbers, 911, 900 numbers, or toll-free 800, 888, 877, or 866 numbers.
- We may provide your name, address, and telephone number to public safety authorities and their vendors for inclusion in E911 databases and records, inclusion in "reverse 911" systems, or to troubleshoot 911/E911 record errors.
- We may publish and distribute, or cause to be published and distributed, telephone directories in print, on the Internet, and on disks. Those telephone directories may include customer names, addresses, and telephone numbers, without restriction to their use.
- We also may make your name, address, and telephone number(s) available, or cause such subscriber information to be made available, through directory assistance operators.
- We may provide your name, address, and telephone number(s) to unaffiliated directory publishers and directory assistance providers for their use in creating directories and offering directory assistance services.
- Once our customers' names, addresses, and telephone numbers appear in telephone directories or directory assistance, they may be sorted, packaged, repackaged and made available again in different formats by anyone.
We take reasonable precautions to ensure that non-published and unlisted numbers are not included in our telephone directories or directory assistance services, or in those provided by unaffiliated directory publishers or directory assistance providers, but we cannot guarantee that errors will never occur. We may charge an additional fee to subscribers who choose to have non-published or unlisted numbers. Further, we may have no control over information appearing in the directory lists or directory assistance services of unaffiliated directory publishers or directory assistance providers.
When does Insight disclose information to Government Entities or others pursuant to legal process?
We may be required by law to disclose personally identifiable information or individually identifiable CPNI about a customer without his or her consent and without notice in order to comply with a valid legal process such as a subpoena, court order, or search warrant.
For customers to our cable television service, the Cable Act permits us as a cable operator to disclose personally identifiable information to a third-party or governmental entity in response to a court order. If the court order is sought by a non-governmental entity, we are required to notify the customer of the court order. If the court order is sought by a governmental entity, the Cable Act generally requires that the cable customer be afforded the opportunity to appear and contest in a court proceeding relevant to the court order any claims made in support of the court order. At the proceeding, the Cable Act requires the governmental entity to offer clear and convincing evidence that the subject of the information is reasonably suspected of engaging in criminal activity and that the information sought would be material evidence in the case.
For customers to our high-speed Internet and phone services, the Cable Act requires us to disclose personally identifiable information to a private third party in response to a court order, and we are required to notify the customer of the court order. The Cable Act also requires us to disclose personally identifiable information about customers to high-speed Internet and phone services to a government entity in response to a subpoena, court order, or search warrant, for example.
If you are a customer of our high speed Internet or phone service, the Electronic Communications Privacy Act (the "ECPA") requires us to reveal information to the government in certain additional circumstances. The ECPA addresses both the content of communications transmitted via our high speed Internet services, as well as customer record information. The ECPA requires us to disclose to governmental authorities the content of communications in response to a criminal warrant or court order without any notice to you and without your consent. In addition, under the ECPA, a law enforcement or governmental agency may require Insight to disclose customer record information (but not the content of communications) pursuant to a warrant, court order or subpoena, without any notice to you and without your consent.
If you subscribe to our high speed Internet service, a private party also may use a subpoena under the Copyright Act to obtain information about you to bring a copyright infringement suit against the posting of online material, without any notice to you.
In your Subscription Agreement, you have agreed that Operator and our Affiliated ISPs may also disclose any information in its possession to protect its rights, property and/or operations, or where circumstances suggest that individual or public safety is in peril.
How does Insight protect personally identifiable information?
We follow industry-standard practices to take such actions as are necessary to reasonably restrict unauthorized access to a customer's personally identifiable information. However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose personally identifiable information.
How long does Insight maintain personally identifiable information?
We maintain personally identifiable information about you in our regular business records while you are a customer to our cable service or other services. We also maintain this information for a period of time after you are no longer a customer if the information is necessary for the purposes for which it was collected or to satisfy legal requirements. These purposes typically include business, legal, or tax purposes. If these purposes no longer apply, we will destroy the information according to our internal record retention policies and procedures.
IV. Customer Access and Choice
How can I see my personally identifiable information or CPNI and correct it, if necessary?
You may examine and correct, if necessary, the personally identifiable information regarding you that is collected and maintained by Insight in our regular business records. In most cases, the personally identifiable information contained in these records consists solely of billing and account information. We will correct our records if you notify us of any inaccuracies regarding the personally identifiable information of yours that we maintain.
You can view and change certain of your personally identifiable information at your local Insight office upon reasonable prior notice to us and during our regular business hours. If you wish to examine these records, please contact your local Insight office. Please allow us a reasonable period of time to locate and, if necessary, prepare the information for review, and to arrange an appointment. You will only be permitted to examine records that contain personally identifiable information about your account and no other account.
If you make an affirmative, written request for a copy of your CPNI, we will disclose the relevant information we have to you at your account address of record, or to any person authorized by you, if we reasonably believe the request is valid. However, subscribers to our phone services should be aware that we generally do not provide them with records of any inbound or outbound calls or other records that we don't furnish in the ordinary course of business (for example, as part of a bill) or which are available only from our archives, without valid legal process such as a court order. In addition, we cannot correct any errors in customer names, addresses, or telephone numbers appearing in, or omitted from, our vendors' directory lists until the next available publication of those directory lists. Further, we may have no control over information appearing in the directory lists or directory assistance services of directory publishers or directory assistance providers which are not owned by us or our subsidiaries.
We reserve the right to charge you for the cost of retrieving and photocopying any documents that you request.
When will I receive notices or information about changes to this policy?
We will provide you with a copy of our privacy policy at the time we enter into an agreement to provide any cable service or other service to you and annually afterwards, or as otherwise required by law. You may view the most current version of this policy on our website. We may modify this policy at any time. We will notify you of any material changes through written, electronic, or other means and as otherwise permitted by law. If you find the changes to this policy unacceptable, you have the right to cancel your service. If you continue to use the service following notice of the changes, we will consider that to be your acceptance of and consent to the changes in the revised privacy policy. This includes your consent for any personally identifiable information that we may collect and use starting on the effective date of the revised policy, as well as for any personally identifiable information that we have collected prior to the effective date of the revised policy.
What can I do if I have questions or concerns about my privacy rights?
We encourage you to contact us directly as described below in "How do I contact Insight?" in order to resolve your question or concern.
If you have any questions or suggestions regarding this privacy policy, or wish to contact us about your personal information, please contact us at the following address:
Insight Communications
810 Seventh Avenue, 41st Floor
New York, New York 10019
Attention: Legal Department
Last Revision Date: September 15, 2008