Privacy Policy

 

Mark Twain Rural Telephone Company and Mark Twain Communications Company (hereinafter “Company,” “we,” “our,” “us”) are committed to respecting and protecting the privacy of our customers.  Protecting your private information or Personally Identifiable Information is our priority. This Privacy Policy explains the types of personal information we collect, and how we collect, use, maintain, protect, and share this information. This Privacy Policy also tells you about the rights and choices you may have when it comes to your personal information.

 

This Privacy Policy applies to the information we collect when you use or interact with our products, services, and networks (“Services”), including www.marktwain.net (“Website”), but it is not exclusive to it. This Privacy Policy applies to everyone, including, but not limited to, visitors, users, and others who wish to access our Services or Website. By using our Services or Website, you consent to the data practices described in this Privacy Policy.

 

Please read this Privacy Policy carefully to understand our policies and practices regarding your information.

 

Definitions

 

  • Personal Identifiable Information or “personal information” refers to any information that can be used to identify a specific individual. This includes information that is directly linked to a person, such as their name, date of birth, social security number, or email address, as well as information that can be used to identify them indirectly, such as their physical characteristics, biometric data, or online identifiers like IP addresses or device identifiers.

 

  • Allowable Tracked Information refers to the specific types of data that a website or application is permitted to collect, use, and share with third parties. Examples of allowable tracked information that a website or application may collect and use could include: User behavior data, such as website usage patterns, search history, or clickstream data; location data, such as GPS data or IP address; network data, such as bandwidth usage, transmissions, security characteristics, content, or other network resources used in connections while uploading, downloading, or streaming; performance data, such as IP or Mac addresses, URLs, data transmission rates and latencies; equipment data, such as equipment type, serial number, settings, configurations, or software; demographic information, such as age, gender, or occupation; contact information, such as email address or phone number; or financial information, such as credit card numbers or payment information.

 

  • Third Party refers to any entity that is not directly affiliated with us or our Website that is collecting or processing user data. This can include companies that provide services or products to the Company, analytics providers, or other third-party service providers.  Examples of third parties that may be involved in the collection and processing of user data include: Analytics providers that collect data on user behavior and provide insights to the organization, or payment processors or financial institutions that process transactions and collect payment information, etc.

 

  • Cookies refer to text files placed on a computer, mobile phone, or other device used to navigate the internet. Cookies transmit information back to the website’s server about the browsing activities of the user and may also be used to collect and store information about your preferences after you visit a website.

 

Collection of Your Personal Information

 

We limit the collection, use, retention, and disclosure of personal information to what is reasonably necessary and proportionate to achieve the purposes for which the personal information was collected or processed. We also limit secondary use to that which is compatible with the original purpose of the personal information collection.

 

When you visit our Website, you may provide us with two types of information: personal information that you knowingly choose to disclose that is collected on an individualized basis, and website use information collected on an aggregate basis as you and others browse our Website.

 

You may also be required to provide certain personal information to us when you elect to use certain products or services by (a) registering for an account, (b) sending us an email message, and (c) submitting your credit card or other payment information when ordering and purchasing products and services.

 

We will use your information to communicate with you about services and/or products you have requested from us, including, but not limited to, providing them. We use information about customers in defined and responsible ways to manage, provide, and improve our products, services, and operations for our customers. This information will be used for internal purposes only and will not be shared with any third party. It shall not be used for any improper or unlawful purpose.

 

We retain customer information for such periods of time as required by law or regulation or as reasonably necessary to provide services.

 

Aggregate or Generic Information

 

This Privacy Policy does not apply to aggregate and/or generic information that does not identify you or any individual. Therefore, we reserve the right to share non-personal information with third parties for any reason, unless prohibited by law or regulation.

 

 

Right to Review and Update Your Personal Information

You may have a right to correct, update, delete, or request access to the personal information that you have provided to us. You may submit the following request to csrs@marktwain.coop or 660-423-5211. 

For your protection, we will only implement requests with respect to personal information about you (not anyone else), and we may need to verify your identity before implementing your request. We may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations. And even if you have a right to deletion, some of your information may remain within our systems and other records or archives, in compliance with applicable law.

 

Sharing Information with Third Parties

 

We do not share customer information with third parties, except at the customer’s request, with the customer’s consent, or as described below. We do not sell, rent, or lease its customer lists to third parties.

 

We may share allowable tracked information with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. This information will not include personal information.  All such third parties are prohibited from using your personal information except to provide these services to the Company, and they are required to maintain the confidentiality of your information.

 

Representative third parties include:

 

Vendors: We may provide information to our vendors who help us do things like provide service features, monitor Website activity, maintain databases, and assist us in hosting, and where they may observe information about you in the same way as described herein. We also use third-party vendors to provide services related to hosting the Website, providing technical support, updating records in our database, and sending or coordinating marketing communications on our behalf.

 

Marketing: The information you provide on the Website may also be used by us for marketing purposes, such as when you subscribe to receive marketing communications or newsletters. Your information will not be provided to third parties for any third-party marketing purposes. You may choose to stop receiving our marketing communications at any time by opting out by following the unsubscribed instructions included in those communications, or you can contact us at csrs@marktwain.coop or 660-423-5211, and we will remove you from future mailings.

 

Third-Party Support: While not routine, we may provide your information to persons or entities in connection with our own business operations, such as to contractors, our auditors, or counsel, or in connection with a major change in our business (such as an acquisition). In these instances, the Company will ensure that such persons or entities are subject to obligations to keep the information confidential and use the information only for the purpose we provided it to them.

 

We may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on the Company or the site; (b) protect and defend the rights or property of the Company; and/or (c) act under exigent circumstances to protect the personal safety of users or the public.

 

Automatically Collected Information

 

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect allowable tracked information about your equipment, browsing actions, and patterns, including:

 

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data, and the resources that you access and use on the Website.
  • Information about your device and internet connection, including your IP address, operating system, domain names, access times, and browser type.

 

We use this allowable tracked information to operate the Website, maintain the quality of the Website, and assess Website usage.

 

Use of Cookies

 

The Website may use “cookies” to personalize your online experience. Cookies are small pieces of data that are stored by a user’s web browser on the user’s hard drive. One of the primary purposes of cookies is to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize website pages or register with our Website or Services, a cookie helps us to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, etc. When you return to the same website, you can easily retrieve the information you previously provided.

 

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our Services or our Website.

 

Links

 

This Website may contain links to other sites. We provide such links for your reference only. Please be aware that we are not responsible for the content or privacy practices of such other sites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. We encourage our users to be aware when they leave our site and to read the privacy policies of any other site that collects Personally Identifiable Information.

 

 

 

 

E-mail Communications

 

From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. To improve our Services, we may receive a notification when you open an email from us or click on a link therein.

 

If you would like to stop receiving marketing or promotional communications via email from us, you may opt out of such communications by clicking the “Unsubscribe” button at the bottom of the email.

 

If you choose to correspond with us through email, we may retain the content of your email messages along with your email address and our responses. We also may send automated messages to you pertaining to your account, such as billing invoices and other notices. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail or telephone. We ask that you not provide us with confidential information such as social security or account numbers through unsecured email. You may also contact us by phone, U.S. mail, or by visiting our location.

 

Children

 

We do not provide services to children, as defined under applicable law. Our Website is not targeted or marketed to children. We respect the privacy of your children, and we comply with the practices established under the Children’s Online Privacy Protection Act. We do not knowingly collect or retain personally identifiable information from children. If you believe that a child has provided their information to us through our Website or Services, please contact us at csrs@marktwain.coop or 660-423-5211 so that we can take steps to delete it.

 

Security of Your Personal Information

 

All our employees are responsible for safeguarding individual customer communications and information.

 

  • We take reasonable precautions to protect personal information against unauthorized access. We require all personnel to protect the privacy of all forms of customer communications as well as individual customer records.
  • We secure all customer personal information from unauthorized access, use, or disclosure with Secure Sockets Layers protocol (SSL). This technology encrypts, or scrambles, your information so it’s virtually impossible to read by anyone other than employees at our Company. SSL technology secretly encodes information that is being sent over the Internet between your computer and our website, helping to ensure that the information remains confidential.
  • We use SSL protocol to protect your personal information when you interact with a third-party website (such as when making a payment). Once the data is transmitted, the third party’s policies will govern the protection of your personal information.

 

We strive to take appropriate, commercially acceptable security measures to protect against unauthorized access to or alteration of your personal information. While we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet that are beyond our control; and (b) security, integrity, and privacy of information and data exchanged between you and us through this Website cannot be guaranteed; and (c) no method of transmission over the internet, or method of electronic storage is one hundred percent secure. Any transmission of information over the internet is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website by any person or entity.

 

CPNI Notice

 

Customer Proprietary Network Information (“CPNI”) is created by our relationship with you as your telecommunications service provider. In the course of providing service to telephone customers, we collect information concerning the telephone services you purchase and how you use them.

CPNI includes any information on the quantity, technical configuration, type, destination, location, and amount of use of your service that we obtain because we are your telephone carrier. CPNI includes the type and quantity of certain telecommunications services you subscribe to and details about your calling activities, including call detail information such as the date and time of a call, the duration of a call, and call-originating and call-terminating phone numbers.

CPNI does not include the names, addresses, and telephone numbers published in telephone directories or information we obtain as a result of providing your Internet service.

 

We may use your CPNI to provision your services, generate, bill, and collect for your services, respond to your requests, enforce our Terms of Service, and protect against fraudulent use of our network. Mark Twain does not use CPNI for marketing purposes. Accordingly, Mark Twain’s personnel are trained not to use CPNI for such purposes. Because CPNI is not used for marketing purposes, Mark Twain has established the appropriate safeguards for this type of treatment (non-use) of CPNI data. These safeguards include documentation of this policy in company procedures and training of company personnel with regard to non-use of CPNI data. The Company does not currently solicit “opt out” or “opt in” customer approval for the use or disclosure of CPNI.  The Company does not use CPNI for marketing purposes and does not disclose or grant access to CPNI to any party (including to agents or affiliates that provide communications-related services), except as permitted under 47 U.S.C. § 222(d) and Rule 64.2005.

We are committed to ensuring that only properly authorized individuals are able to access CPNI for legitimate purposes. This includes ensuring that any request by a “customer” to access CPNI is valid and properly authenticated, in accordance with applicable law and industry best practices.

 

 

We are vigilant in our efforts to protect your CPNI. However, should we become aware that your CPNI has been accessed without proper authority, we will take swift action to fully document and address such unauthorized access and provide appropriate notice. In particular, we will (i) notify law enforcement (including the United States Secret Service and the Federal Bureau of Investigation) within seven business days; and (ii) notify you and any other affected customers within seven business days thereafter, unless earlier notification is necessary to avoid immediate and irreparable harm, or we are instructed by law enforcement personnel to refrain from providing such notice.

 

Changes to Our Privacy Policy

 

We reserve the right to change, modify, or update this Privacy Policy at any time without notice. In the event of any modification, we will post the changes in this Privacy Policy so that you will always know what information we are gathering and how we might use that information. Accordingly, you should periodically visit this page to determine the current Privacy Policy to which you are bound.

 

 

 

 

Contact Information

 

If you have a question or comment about this Privacy Policy, please call our business office at 660-423-5211 between 8:00 am and 4:45 pm Monday through Friday or email csrs@marktwain.coop.