COMPAS X-STREAM takes the protection of our subscribers' ("You," "Your" or "Customer(s)") privacy seriously. The following privacy policy ("Policy") applies to those COMPAS X-STREAM residential Customers who subscribe to COMPAS X-STREAM's residential video programming, high-speed Internet and/or telephone service (individually and collectively the "Service") and describes the Customer information that COMPAS X-STREAM collects and retains, how COMPAS X-STREAM uses and protects it, the limited cases where COMPAS X-STREAM may disclose some or all of that information, and Your rights under the Cable Communications Policy Act of 1984 ("Cable Act"). Depending upon the COMPAS X-STREAM Service to which You subscribe, parts of this Policy may not be applicable to You. COMPAS X-STREAM values Your privacy and considers all personally identifiable information contained in our business records to be confidential. Please review this Policy and, if You are a COMPAS X-STREAM telephone service subscriber, the attached Customer Proprietary Network Information ("CPNI") Policy (the "CPNI Policy"), in conjunction with Your service agreement, terms of service and acceptable use policy ("Your Service Agreement"). COMPAS X-STREAM will provide You copies of this Policy annually and the CPNI Policy at least once every two years, whether or not we have revised the policies. We may modify this Policy at any time. The most current version of this Policy can be found on www.compascable.net. If you find the changes unacceptable and if those changes materially and adversely impact Your use of the Service, You may have the right to cancel Your Service under Your Service Agreement. If You continue to use the Service following the posting of a revised Policy, we will consider that to be Your acceptance of and consent to the Policy as revised.

 

What type of information does COMPAS X-STREAM collect?

COMPAS X-STREAM collects both personally identifiable information and non-personal information about You when You subscribe to our Service. COMPAS X-STREAM uses its system to collect personally identifiable information about You: (a) when it is necessary to provide our services to You; (b) to prevent unauthorized reception of our services; and (c) as otherwise provided in this Policy. COMPAS X-STREAM will not use the system to collect Your personally identifiable information for other purposes without Your prior written or electronic consent. COMPAS X-STREAM also collects personally identifiable and non-personal information about You when You voluntarily provide information to COMPAS X-STREAM, as may be required under applicable law, and from third parties, as described in this Policy.

Personally identifiable information is any information that identifies or can potentially be used to identify, contact, or locate You. This includes information that is used in a way that is personally identifiable, including linking it with identifiable information from other sources, or from which other personally identifiable information can easily be derived, including, but not limited to, name, address, phone or fax number, email address, spouses or other relatives' names, drivers license or state identification number, financial profiles, social security number, bank account information, and credit card information. Personally identifiable information does not include information that is collected anonymously (i.e., without identification of the individual or household) or demographic information not connected to an identified individual or household.

Non-personal information, which may or may not be aggregated information about our Customers and may include information from third parties, does not identify individual Customers. COMPAS X-STREAM may combine third party data with our business records as necessary to better serve our Customers. Examples of non-personal information include IP addresses, MAC addresses or other equipment identifiers, among other data. Our systems may automatically collect certain non-personal information when You use an interactive or transactional service. This information is generally required to provide the service and is used to carry out requests a Customer makes through a remote control or set-top box.

We may also collect and maintain information about Your account, such as billing, payment and deposit history; maintenance and complaint information; correspondence with or from You, information about the service options that You have chosen; information the equipment You have, including specific equipment identifiers; and information about Your use of our services, including the type, technical arrangement, quantity, destination and amount of use of certain of those services, and related billing for those services.

COMPAS X-STREAM also collects customer-provided customization settings and preferences. By using our service, You consent to our collection of this information and other information communicated to COMPAS X-STREAM such as correspondence, responses to surveys or emails, information provided in chat sessions with us, registration information, or participation in promotions or contests.

If You subscribe to our video service, then in certain of our systems, our set-top boxes automatically collect information that may be used to determine which programs are most popular, how many set-top boxes are tuned to watch a program to its conclusion and whether commercials are being watched, as well as other audience-measurement focused information. Our processes are designed to track this information and audience statistics on an anonymous basis. Information such as channel tuning, the time the channel is changed, and when the set-top box is "on" or "off" is collected at a secure database in an anonymous format. COMPAS X-STREAM, or our contractors or agents, may from time to time share the anonymous information with our advertisers, content providers, or other third parties with whom we have a relationship. We will not provide our advertisers, content providers, or these other third parties with personally identifiable information about You unless we have received Your consent first, except as required by law. (See "Who sees the information collected by COMPAS X-STREAM" below.)

 

Why does COMPAS X-STREAM collect personally identifiable information?

COMPAS X-STREAM collects and uses personally identifiable information to:

• properly deliver our Services to You;

• provide You with accurate and high quality customer service;

• perform billing, invoicing and collections;

• provide updates, upgrades, repairs or replacements for any of our service-related devices or software used in providing or receiving services;

• protect the security of the system, prevent fraud, detect unauthorized reception, use, and abuse of COMPAS X-STREAM's Services or violations of our policies or terms of service;

• keep You informed of new or available products and services;

• better understand how the Service is being used and to improve the Service;

• manage and configure our device(s), system(s) and network(s);

• maintain our accounting, tax and other records; and

• comply with applicable federal and state laws and regulations, as well as for the general administration of our business.

If You use an interactive or transactional service, for example, responding to a survey or ordering a pay-per-view event, the system will collect certain additional personally identifiable information, such as account and billing information or Customer-provided locale and service preferences, to properly bill You for the services purchased and to provide You with a more personalized experience. In addition, certain information such as Your connections to our system is automatically collected to, for example, make it possible for Your digital boxes to receive and process the signals for the services You order.

COMPAS X-STREAM may also collect personally identifiable information from third parties to enhance our customer database for use in marketing and other activities. COMPAS X-STREAM also collects personally identifiable information from third parties to verify information You have provided us and collects personally identifiable information from credit reporting agencies to, for example, determine Your creditworthiness, credit score, and credit usage. COMPAS X-STREAM also may maintain research records containing information obtained through voluntary subscriber interviews or surveys.

If You subscribe to our high-speed Internet service, COMPAS X-STREAM transmits personally identifiable and non-personal identifiable information about You over the Service when You send and receive e-mail and instant messages, transfer and share files, make files accessible, visit websites, or otherwise use the Service and its features. Our transmission of this information is necessary to allow You to use the Service as You have chosen and to render the Service to You.

 

Who sees the information collected by COMPAS X-STREAM?

COMPAS X-STREAM will only disclose personally identifiable information to others if: (a) Customer provides written or electronic consent in advance, or (b) it is permitted or required under federal or applicable state law. Specifically, federal law allows COMPAS X-STREAM to disclose personally identifiable information to third parties:

• when it is necessary to provide COMPAS X-STREAM's services or to carry out COMPAS X-STREAM's business activities;

• as required by law or legal process; or

• for mailing list or other purposes, subject to Your ability to limit this last type of disclosure.

To provide services and carry out our business activities, certain authorized people have access to Your information, including our employees, entities affiliated through common ownership or control with COMPAS X-STREAM and third parties that provide and/or include: billing and collection services; installation, repair and customer service subcontractors or agents; program guide distributors; software vendors; program and other service suppliers for audit purposes; marketers of COMPAS X-STREAM's products and services; third party auditors; our attorneys and accountants; and/or strategic partners offering or providing products or services jointly or on behalf of COMPAS X-STREAM. The frequency of disclosures varies according to business needs, and may involve access on a regular basis. COMPAS X-STREAM restricts third parties' use of Your information to the purposes for which it is disclosed and prohibits third parties from further disclosure or use of Your personally identifiable information obtained from us, whether for that third party's own marketing purposes or otherwise.

Unless You object in advance, federal law also allows COMPAS X-STREAM to disclose through "mailing lists," personally identifiable information, such as Your name, address and the level of Your service subscription, to non-affiliated entities, including advertisers and marketing entities, for non-service related purposes, including product advertisement, direct marketing and research. Under no circumstances will COMPAS X-STREAM disclose to these advertising entities the extent of Your viewing habits or the transactions You make over the system. COMPAS X-STREAM, or our contractors or agents, may from time to time share non-personal and/or aggregate information such as the number of Service subscribers who match certain statistical profiles (for example, the number of subscribers in various parts of the country) with our advertisers, content providers, or other third parties with whom we have a relationship.

We may provide anonymous data to third parties who may combine it with other information to conduct more comprehensive audience analysis for us and for television advertisers. This data helps program networks and cable operators decide on which programs, channels, and advertising to carry. COMPAS X-STREAM may also use that information to distribute targeted advertising to You without having disclosed any of Your personally identifiable information to the advertisers. These advertisements may invite interactive or transactional follow-up from You. By using any of COMPAS X-STREAM's interactive services, You consent to our collection of this additional information. Unless You consent first or except as required by law, only anonymous information is disclosed to audience measurement services.

As part of its business activities, if COMPAS X-STREAM enters into a merger, acquisition, or sale of all or a portion of our assets, COMPAS X-STREAM may transfer Customers' personally identifiable and non-personal information as part of the transaction.

If You subscribe to our telephone service, Your name, address and/or telephone number may be transmitted via Caller ID, published and distributed in affiliated or unaffiliated telephone directories, and available through affiliated or unaffiliated directory assistance operators. We take reasonable precautions to ensure that non-published and non-listed numbers are not included in the telephone directories or directory assistance services, although we cannot guarantee that errors will never occur. Please note that Caller ID blocking may not prevent the display of Your name and/or telephone number when You dial certain business numbers, 911, 900 numbers or toll-free 800, 866, 877 or 888 numbers.

If allowed by and after complying with any federal law requirements, COMPAS X-STREAM may disclose personally identifiable information about Customer to representatives of government or to comply with valid legal process, except as provided below, disclosures shall not include records revealing Customer's selection of video programming. Disclosures to representatives of government may be made pursuant to an administrative subpoena, warrant, court order, our reasonable discretion in cases of emergency or serious physical injury, or other permitted means. In these situations, COMPAS X-STREAM may be required to disclose personally identifiable information about a Customer without Customer's consent and without notice to the Customer. Law enforcement agencies may, by federal or state court order, and without notice to You, obtain the right to install a device that monitors Your Internet and e-mail use, including addresses of email sent and received and in some cases the content of those communications; and/or Your use of our telephone service, including listings of incoming and outgoing calls and in some cases the content of those calls. In some instances where there are valid legal requests for or orders for disclosure of Your information, we may notify You of the requests or orders and then it may be up to You to object or take specific action to prevent any disclosures pursuant to those requests or orders.

Where a governmental entity is seeking personally identifiable information of a Customer who subscribes to COMPAS X-STREAM's video services only or records revealing Customer's selection of video programming, the Cable Act requires a court order and that the video subscriber 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 such a 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 prosecution of the case. Except in certain situations (such as with respect to those who owe, or are owed, welfare or child support) state welfare agencies may obtain the names, addresses, and certain other Customer information as it appears in COMPAS X-STREAM's subscriber records under the authority of an administrative subpoena.

We may also use or disclose personally identifiable information about You without Your consent (a) to protect our Customers, employees, or property, (b) in emergency situations, (c) to enforce our rights in court or elsewhere, or directly with You, for violations of service terms, conditions or policies and/or (d) in order to comply with the Digital Millennium Copyright Act or as otherwise required by law, for example, as part of a regulatory proceeding.

 

Can I prohibit or limit COMPAS X-STREAM's use and disclosure of my personally identifiable information?

If You do not want Your name, address, level of service or other personally identifiable information disclosed to third parties in a "mailing list" as explained above, or if You do not want to receive marketing messages (e.g., phone calls, emails, and direct mail) please email this preference to This email address is being protected from spambots. You need JavaScript enabled to view it. or by contacting us by telephone at 1-828-438-5353. Customers of our video service cannot opt-out of the collection of audience measurement data. Please note that such request will not eliminate all telephone calls, emails or direct mail sent to You from COMPAS X-STREAM as COMPAS X-STREAM may still continue to send non-marketing account-related messages to You.

 

How long does COMPAS X-STREAM maintain personally identifiable information?

COMPAS X-STREAM will maintain personally identifiable information about You as long as You are a subscriber to COMPAS X-STREAM's Service and as long as necessary for the purpose for which it was collected. If You are no longer a subscriber to any COMPAS X-STREAM Service and the information is no longer necessary for the purpose for which it was collected, COMPAS X-STREAM will only keep personally identifiable information as long as necessary to comply with laws governing our business. These laws include, but are not limited to, tax and accounting requirements that require record retention. COMPAS X-STREAM will also maintain personally identifiable information to satisfy pending requests for access by a subscriber to his/her information or pursuant to a court order. COMPAS X-STREAM will destroy Customers' personally identifiable information when the information is no longer necessary for the purpose for which it was collected, when there are no longer pending requests for such information, and when it is no longer necessary to retain the information under applicable laws.

 

How does COMPAS X-STREAM protect customer information?

COMPAS X-STREAM takes the security of our Customers' personally identifiable information seriously. COMPAS X-STREAM takes such actions as are reasonably necessary to prevent unauthorized access by entities other than COMPAS X-STREAM to personally identifiable information. COMPAS X-STREAM uses security and/or encryption technology to secure certain sensitive personally identifiable information when it collects such information over the system. COMPAS X-STREAM restricts access to its customer database and secures the content by use of firewalls and other security methods. COMPAS X-STREAM limits access to databases containing Customers' personally identifiable information to those specifically authorized employees and agents of COMPAS X-STREAM and other parties identified in the "Who sees the information collected by COMPAS X-STREAM?" section above. However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose personally identifiable information.

You need to help protect the privacy of Your own information. You and others who use Your equipment must not give identifying information to strangers or others whom You are not certain have a right or need to the information. You also must take precautions to protect the security of any personally identifiable information that You may transmit over any home networks, wireless routers, wireless fidelity (WiFi) networks or similar devices by using encryption and other techniques to prevent unauthorized persons from intercepting or receiving any of Your personally identifiable information. You are responsible for the security of Your information when using unencrypted, open access or otherwise unsecured networks in Your home. For more information on things You can do to help protect the privacy of Your own information, visit http://www.onguardonline.gov/.

 

Can I see the information that COMPAS X-STREAM collects about me?

You have a right under the Cable Act to see Your personally identifiable information that COMPAS X-STREAM collects and maintains. The information COMPAS X-STREAM has about its Customers is maintained at COMPAS X-STREAM's local office in City Hall at 305 E. Union St. in Morganton. If You would like to see Your information, please send a written request to COMPAS X-STREAM. COMPAS X-STREAM will be glad to make an appointment for You to come in to our office during regular business hours. If Your review reveals an error in our records, COMPAS X-STREAM will correct it. You may also be able to access certain information about You or Your account by telephone (1-828-438-5353), depending upon the information You have provided.

 

Does COMPAS X-STREAM protect children's privacy?

COMPAS X-STREAM is concerned about children's privacy and does not knowingly collect personally identifiable information from anyone under the age of 13 over its Service unless otherwise expressly identified. COMPAS X-STREAM urges children to always obtain a parent or legal guardian's permission before sending any information about themselves over the Internet and urges parents and legal guardians to be vigilant regarding children's Internet usage. Other services or web pages accessed through COMPAS X-STREAM's Service may have different policies on collection of information pertaining to children and You should consult their privacy policies and read their notices if You have any concerns about the collection or use of such information by those entities.

 

What if I have any questions?

If You have any questions about our privacy protections and policies, please contact our customer service office at 1-828-438-5353 or by visiting COMPAS X-STREAM's website at www.compascable.net.

 

Effective: April 27, 2010

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