Privacy Policy

This Privacy Policy (“Policy”) describes how Stonehenge Telecom will collect, access, use or disclose your personal information. It applies to all of our products, services, and web sites (“Services”). A few of our Services are covered by different privacy policies and in the event of a conflict between the two, the product or service specific policy governs. For example, we may have a separate policy or agreement for certain products, services or brands. We may also give you extra notices about your personal information. Your personal information is subject to U.S. law.

• INFORMATION COLLECTED
• USE OF PERSONAL INFORMATION
• INFORMATION WE SHARE
• NETWORK AND INFORMATION SECURITY
• INFORMATION CHOICES AND CHANGES
• CONTACTING US
• UPDATING THIS POLICY
• YOUR CALIFORNIA PRIVACY RIGHTS
• INTERNATIONAL DATA PRIVACY POLICY

INFORMATION COLLECTED
We collect personal information about you in various ways. We may also get information from other sources and may combine it with information we collect about you.

Information you give us. The personal information we collect includes information you give us such as name, postal address, telephone number, e-mail address, date of birth, social security number or other government identification number, demographics, activities, location information, and personal preferences. You may give us information in a variety of ways such as when you sign up for Services, communicate with customer care or register on www.stonehenge-telecom.com. Personal information does not include information that is not used to identify you including aggregate or anonymous information.

Information that we automatically collect. We automatically receive certain types of information whenever you use our Services. We may collect information about your device, your computer, and online activities. For example, we collect your device’s and computer’s IP address, the date and time of your access and the type of browser you use. We also collect information about your device’s and computer’s operating system, your location, and the Web site from which you came and then went and Web sites you visit on your device. We may link information we automatically collect with personal information, such as information you give us at registration or check out.

Information we collect when we provide you with Services includes when your wireless device is turned on, how your device is functioning, device signal strength, where it is located, what device you are using, what you have purchased with your device, how you are using it, and what sites you visit.

We may use systems or tools to follow your use of our Services, including using cookies, web beacons and other tracking mechanisms. For example, we allow collection by analytic service provider(s) of site click-stream and cookie data to help us track aggregate and individual use of our Services. We sometimes use cookies to enable features on our sites, like the ability to save your shopping cart or set preferences. Advertisers and advertising networks that serve ads on our sites may also use their own mechanisms, like cookies. These third party cookies are governed by the privacy policies of the entities placing the ads and are not subject to this Policy.

USE OF PERSONAL INFORMATION

We use your personal information for a variety of purposes, including providing you with Services. We use your personal information to do things like:
• Process your orders.
• Protect our and our customers’ rights and property.
• Respond to legal process and emergencies.
• Develop or inform you of new products and services.
• Anonymize or aggregate personal information for various purposes like market analysis or traffic flow analysis and reporting.
• Customize or personalize your experience with our Services.
• Customize or personalize advertising and communications to bring you information about products and services of Stonehenge Telecom or others that may interest you, including co-branded offers. For example, we may customize the ads you see when you are using our Internet-enabled devices. If we use information about your online activities to deliver advertising or communications tailored to your interests, we may share that information with third parties who select tailored advertising.
• Monitor, evaluate or improve our Services, systems, or networks.

INFORMATION WE SHARE

We may share information that is anonymized or in an aggregated form that does not directly identify you. We do not share your personal information with third parties other than as follows:

Service Providers. We may share personal information with third parties who perform services on our behalf.

Group Account Holders. We offer group accounts to business and government customers, family customers and other group account holders (“Group Accounts”). The account holder for Group Accounts is the entity or person that buys the service or product for its employees, family members or other authorized users. You (as the user of a device) may receive service, certain pricing, terms or other benefits through a Group Account with us. If so, we may share with that Group Account holder customer registration and other information related to your use of our services.

Other Third Parties with Your Consent. We may share information with other third parties with your consent. For example, you may agree to our sharing your information with other third parties to hear about their products and services. Use of the information you agree to share will be subject to those third parties’ separate privacy policies.

Disclosures to Third Party Application and Service Providers. You may choose to use services and products offered by third parties through our Services or devices like third party applications. When you leave our network you may also use mobile roaming services provided by third parties. Your use of such services and applications may result in these third parties collecting your personal information and obtaining information from Stonehenge Telecom, including location information (when applicable). You may also choose to give personal information directly to third parties when using our Services. In each case, personal information you give a third party will be subject to its terms, conditions, and policies –not this policy. You should review a third party’s privacy policy and terms of service before providing your information or using the service.

Business Transfers. Personal information about you may be disclosed as part of any merger, acquisition, sale of company assets or transition of service to another provider. In the unlikely event of an insolvency, bankruptcy or receivership, personal information may also be transferred as a business asset.

Protection of Stonehenge Telecom and Others. We may access, monitor, use or disclose your personal information or communications to do things like:

• comply with the law or respond to lawful requests or legal process;
• protect the rights or property of us, our agents, members, our customers, and others including to enforce our agreements, policies and terms of use
• respond to emergencies;
• initiate, render, bill, and collect for services; or
• facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government requirement; or determine eligibility for government benefits.

NETWORK AND INFORMATION SECURITY

We maintain a variety of physical, electronic, and procedural safeguards. These safeguards help protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. You can learn more about how you can protect your information by reviewing our privacy FAQs.

INFORMATION CHOICES AND CHANGES

We offer you choices regarding how we contact you for marketing related communications and whether we use information regarding your online activities for marketing purposes. Visit www.stonehenge-telecom.com/privacy to learn about ways to register your privacy preferences with us. You may also register a do not contact requests by calling customer care or sending an email to officeofprivacy@stonehenge-telecom.com. If you register a do-not-contact request, we may still contact you for non-promotional purposes, such as emails about your accounts or our ongoing business relations. If you disable cookies on your Internet browser, you also may stop some collection and use of data when you visit our web sites. If you would like to change certain Stonehenge Telecom account information, you may create an online account and manage your account online. For more information, visit www.stonehenge-telecom.com.

CONTACTING US

If you have any questions about, or complaints that concern, this Policy, please call us at Stonehenge Telecom or email us at officeofprivacy@Stonehenge-Telecom.com. If you prefer, you may also write us at Office of Privacy -Legal Department, Stonehenge Telecom, 1101 N. Lake Destiny Road, Suite 120, Maitland, FL 32751, United States. To send us a legal notice relating to this Policy, send it to Our Legal Notices Address listed in, and by the method specified in, the Acceptable Use Policy.

UPDATING THIS POLICY

We may change this Policy at any time. When we change the Policy we will give notice by changing the date it was last updated or as required by law.

YOUR CALIFORNIA PRIVACY RIGHTS

Stonehenge Telecom shares personal information between Stonehenge Telecom affiliates and marketing agents for marketing purposes. We do not share your personal information with unaffiliated third parties for their own independent marketing purposes without your consent. California residents may request the categories of personal information Stonehenge Telecom shared with its affiliates during the previous calendar year. To make your request, send an email to officeofprivacy@stonehenge-telecom.com Written requests may be sent to the Office of Privacy -Legal Department, Stonehenge Telecom, 1101 N. Lake Destiny Road, Suite 120, Maitland, FL 32751, United States. Stonehenge Telecom will respond to these requests within 30 days. Requests that come to Stonehenge Telecom by other means may result in a delayed response.

INTERNATIONAL DATA PRIVACY POLICY

Our International Data Privacy Policy informs you about our practices and policies regarding the collection, use, disclosure, transfer, storage, and processing of personal information in connection with Services offered by Stonehenge Telecom, its subsidiaries, affiliates, and agents (collectively “Stonehenge Telecom”). This policy applies to any personal information collected by Stonehenge Telecom business units outside the U.S.
FAQ

Frequently Asked Questions

DEFINITIONS AND RELATED INFORMATION

Aggregate Information

Information about multiple users that is combined to form information about a group without identifying an individual user.

Anonymous Information

Information where personally identifiable information has been removed or obscured.

Cookies

Cookies are small files placed on your device or computer by a website or an application. These files identify your computer or device and record your preferences and other data about your visit so that when you return, the site or application knows who you are and can personalize your visit. For example, cookies enable a Website shopping cart to function so that you only have to check out once. Cookies are often tied to the use of personally identifiable information while using our site, which means that some functionality may be lost if you choose not to accept the use of cookies.

In general, Stonehenge Telecom uses cookies to (1) help us combat fraud or misuse; (2) personalize your services, special offers, and your overall experience; (3) determine how to improve our Services; (4) learn about your possible interests so that we can further personalize your experience and special offers; (5) retain settings and changes that you made (e.g., if you personalize a page); and (6) complete your transactions.

Third-party advertisers that serve ads on our site may also use their own cookies. These third-party cookies are governed by the privacy policies of the companies placing the ads, and are not subject to this Policy. Visit www.networkadvertising.org to see a list of advertisers that typically serve these kinds of ads and allow you to exercise choices about their use of cookies.

Customer Proprietary Network Information (“CPNI”)

CPNI is information that Stonehenge Telecom develops through a customer’s use of our telecommunication services, like call detail records. The official statutory definition of CPNI is “(A) information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscribed to by any customer of a telecommunications carrier, and that is made available to the carrier by the customer solely by virtue of the carrier-customer relationship; and (B) information contained in the bills pertaining to telephone exchange service or telephone toll service received by a customer of a carrier;…”

Personally Identifiable Information

Information that identifies you, like your name or your personal email address.

Web Beacons

Web beacons (otherwise known as “gifs” or “web bugs”) are electronic images are small, graphical images on a Web page, Web-based document or in an e-mail message that is designed to allow the site owner or a third party to monitor the address and other information of the site. Web beacons are often invisible to the user because they are typically very small (only 1-by-1 pixel) and the same color as the background of the Web page, document or e-mail message. Web beacons are represented as HTML IMG tags in the Web page. Users can click on “view profiles” of the Web page to see whether the page is using a Web beacon.

These images may be used in our Services or emails. We use Web beacons to deliver cookies, count visits, understand usage and campaign effectiveness. We also use Web beacons to tell if an email has been opened and acted upon. Stonehenge Telecom may place “Web beacons” on its sites in conjunction with cookies to see how visitors are navigating and/or interacting with those sites. Web beacons collect the IP address of the computer to which the Web beacon is sent, the URL of the page on which the Web beacon is placed, and the time it was viewed. Web beacons can also be linked to personal information.

PRIVACY QUESTIONS & ANSWERS

What privacy issues should I think about if I use non-Stonehenge Telecom products and services through Stonehenge’s services or devices – things like third party apps.

Many of Stonehenge’s products and services provide an open environment for others to create applications and offer services you might find useful or entertaining. When you choose to use a non-Stonehenge Telecom product or service, like a third-party application or “app,” you may be giving personal information to third parties outside of Stonehenge’s control. If you use an “app” or “widget” or make an online purchase, you may be disclosing personal information directly to the company providing the service or facilitating the transaction. Likewise, if you create a profile in a game, social networking application, or other application or service, post any information, or communicate directly with other users, any personal information you disclose through those activities may be available to third parties other than Stonehenge Telecom. You should review the privacy policies and terms of service of any non-Stonehenge Telecom product or service you choose to use.

How is my device location information used?

To make wireless communications possible, wireless networks use the location of your device to deliver mobile services whenever your device is turned on.

Stonehenge Telecom offers unique features to its users, including a number of location-enabled services that you activate and use. To provide these services, the Stonehenge Telecom network must use the location information of your device to deliver your services. We may also use your location information to create “anonymized” or “aggregate” data from which your personally identifiable information has been removed or obscured.

Your Stonehenge Telecom service may also be personalized using another location identifier, like your zip code. We use this information to serve you relevant content, and we treat the information like any other personal information under our Privacy Policy.

You should carefully review the terms and conditions and privacy policies of third party application and service providers to understand their use of your location information. Only share your location information with those you trust. It is your responsibility to inform anyone that uses your wireless device and all of the users of other wireless devices on your account of location capabilities and the location based services that are in use for those devices.

How does Stonehenge Telecom work to make customer data secure?

We maintain a variety of physical, electronic, and procedural safeguards. These safeguards help protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Privacy programs: Stonehenge Telecom has privacy programs in place to help comply with all applicable privacy laws and regulations. These programs include internal policies and employee training focused on privacy compliance. Our corporate security, fraud, legal and customer care teams regularly evaluate existing safeguards to help protect confidential customer information.

Limited access to call detail information: Our policy is to allow access to CPNI only to those Stonehenge Telecom employees or agents with a “need to know.” For example, customer service agents who need to view this type of information in order to service accounts or answer billing questions.

Code of conduct: Stonehenge Telecom’s Code of Conduct requires employees to take steps to help safeguard confidential customer information. Stonehenge Telecom management requires all employees to follow the Code of Conduct.

Privacy Policy: Stonehenge Telecom customers can access our Privacy Policy online (http://www.stonehege-telecom.com/privacy). The policy sets out how we use and protect customer information.

What can I do to protect my account and information?

You should keep your user name, personal identification number (PIN), password (which may include a shared secret) or other access information safe and confidential to protect against unauthorized access to your account information and services. We strongly encourage you (the account holder) to ensure the privacy of your account information by establishing a PIN for access to your account when you call us on the telephone or when you visit a retail store. You may also manage your account online by creating a user name and a password for Stonehenge Telecom.com. Your PIN, backup shared secret (in case you forget your PIN) and your Stonehenge-telecom user name and password are your authentication credentials.

Establishing and using authenticating credentials are actions you can take to protect yourself. When you elect to use authentication credentials, we will validate those credentials before we allow access to certain of your account information. We treat the holder of your authenticating credentials as an authorized person on your account. Please do not share your authentication credentials with anyone whom you do not wish to access your account.

Stonehenge Telecom urges you to:
• Regularly change your account PIN or online password.
• Adopt passwords that are not commonly used. For example, customers are advised not to use birthdays, social security numbers, anniversaries, etc.
• Passcode protect your voicemail account. Use a passcode to retrieve voicemails rather than opting for the “skip passcode” feature. A feature offered by many wireless companies is “skip passcode,” whereby the customer can access his or her voicemail without having to reenter the password each time. Although some customers find this to be a time-saving, convenient feature, we recommend you password protect your voicemail account to maintain the highest level of security. For example, without a voicemail password, anyone with your device can access the connected voicemail account.
• Contact Stonehenge’s Customer Care department immediately if you believe your account has been accessed without authorization.

What are data brokers and what is “pretexting”?

Numerous companies, known as “data brokers,” operate websites where call detail records and other confidential customer information are offered to anyone willing to pay a fee. These companies claim they can access call detail records or wireless location information, and trace cellular or landline phone calls. These companies do not disclose how they obtain information.

Stonehenge Telecom believes that “pretexting” or “social engineering” is the most common method used to fraudulently obtain private customer information, whereby someone uses personal information from sources other than the wireless company to impersonate an authorized account holder and gain access to a customer’s account without permission from the wireless company or the customer.

How is Stonehenge Telecom taking action against pretexters?

Stonehenge Telecom’s corporate security and legal teams have investigated pretexters. In some instances, Stonehenge Telecom filed lawsuits against companies engaged in fraudulently obtaining and selling customer information.

What should I do if I ever return my device? Any privacy issues to think about?

There are many reasons why you might return your device to Stonehenge Telecom. For example, you may choose to recycle your device when you purchase a new device. Or, you may return your device (under applicable Stonehenge Telecom guidelines/rules) because you are exchanging it. Although in many instances there are processes to remove personal data from returned devices, you should always delete all personal data on your device before returning it. If you don’t know how to remove the data, consult the instruction manual provided with the device or obtain information from the device’s manufacturer.