Southern Ohio Communications Services, Inc. Privacy Policy

And Your California Privacy Rights

Effective Date: October 31, 2020

Southern Ohio Communications Services, Inc. (“SOCS,” “Company,” “us,” “we,” or “our”) values the privacy and security of Customer Personal Information. This Privacy Policy” describes the type of Personal Information SOCS collects, how it is used, disclosed, secured and options regarding certain uses of this information. This Privacy Policy applies to visitors and users of SOCS’s website (“Site”) and applicants and current or former Customers of our VoIP services and Standard and Premium Internet access services (collectively, “Services”) residing in the United States.

Any capitalized terms used herein shall have the same meaning as defined in the SOCS Service Agreements.

By using SOCS’s Site and Services, Customers consent to the data practices described in this Privacy Policy regarding the collection, use, disclosure, and disposal of your Personal Information. SOCS’s Site and Services are designed and targeted to United States audiences and are governed by and operated in accordance with the laws of the U.S. If Customer is not a U.S. citizen or does not reside in the U.S., Customer voluntarily consents to the collection, transfer, use, disclosure and retention of Customer Personal Information in the U.S. Customer also agrees to waive any claims that may arise under Customer’s own national laws.

Your California Privacy Rights

Generally, California residents are entitled by law to ask SOCS for a notice identifying the categories of Personal Information that SOCS that is shared with our Affiliates and/or other third parties for their marketing purposes the preceding year, and provide contact information for such Affiliates and/or third parties unless SOCS meets certain exceptions in the law. This Privacy Policy and Site meet those exceptions. Additionally, SOCS does not share Customer Information to Affiliates or third parties for their own marketing purposes. Therefore, a Customer residing in California with an established business relationship with SOCS, does not need information about SOCS’s opt-out and out-in policies of sharing Customer Personal Information with other companies (including our Affiliates) for their marketing purposes. If you have questions regarding our policy, Customers residing in California must send a written request via email or postal mail following the instructions below. SOCS will not accept requests via the telephone or facsimile or respond to requests that are not labeled or sent properly, or do not have complete information.

● For all requests, include Customer’s full name, street address, city, state and zip code.

● In an email request, Customer must state “Re: Your California Privacy Rights” in the subject line and send Customer email to [Info@Socs.cc]

● In a postal request, Customer must send a letter or post card to:

219 W. Emmitt Ave. Waverly, Ohio, 45690

Attention: Your California Privacy Rights

General Information

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

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

What types of information does this Privacy Policy cover?

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

What Information does SOCS collect and how does SOCS use this Information?

Personal Information

Personal Information is the information Customer provides to SOCS voluntarily or passively through Customer use of the Service and/or website, and which is directly associated with or reasonably linked to a specific person, computer or device. For example, through the registration process, when the equipment to provide the Service is installed, maintained or upgraded at Customer’s premises, when Customer contacts SOCS regarding the Service, and through Customer account settings, SOCS collects Personal Information such as Customer name, email address, phone number, billing address and billing information (such as credit card account number or other financial account information), service address, and the nature of any of Customer devices or other property making use of the Service. Personal Information also includes Customer proprietary network information (“CPNI”) which is collected and used to provide VoIP services. CPNI includes any information that relates to the quantity, technical configuration, type, destination, location, and amount of use of our VoIP service, such as call detail, logs, and specifics regarding your VoIP account. Please note that by law, CPNI does not include a customer’s name, postal address, or telephone number.

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

Non-Personal Information

Website Information, Use of Cookies and other Similar Tracking Technology

When you visit SOCS’s website, SOCS will collect various types of Non-Personal Information, such as information on SOCS server logs from Customer’s browser or device, which may include Customer IP address, unique device identifier, “cookie” information, the type of browser and/or device you’re using to access the Service, and the page or feature Customer requested. (IP Address and device identifiers are traditionally classified as Non-Personal Information, unless SOCS is required to do so otherwise under applicable law.) Cookies” and “web beacons” are text file identifiers SOCS transfers to Customer’s browser or device that allow SOCS to recognize Customer’s browser or device and tell SOCS how and when pages and features on the SOCS website are visited, by how many people, and other activity on the website. Customer can change the preferences on Customer’s browser or device to prevent or limit Customer’s device’s acceptance of cookies, web beacons or other similar technology, but this may prevent Customer from taking advantage of some of the features on the SOCS website, or accessing certain functions and conveniences. If Customer clicks on a link to a third party website or service, such third party may also transmit cookies to Customer. Again, this Privacy Policy does not cover the use of cookies or other such tracking technology by any third parties, and SOCS is not responsible for their privacy policies and practices. SOCS also uses Personal Information and Non-Personal Information to enhance the SOCS website and SOCS Service offerings. For example, such information can tell SOCS how often visitors use a particular feature of the SOCS website and which products and services are most interesting to current and potential customers, and SOCS can use that knowledge to make the website useful and interesting to as many users as possible and to enhance and refine SOCS’s Service offerings. SOCS will continue to conduct analytics on SOCS website performance; Customer may not opt-out of this use of cookies or other Personal Information or Non-Personal Information. Technology is improving every day and to improve SOCS’s Services’ operation and function SOCS may introduce new technologies and monitoring techniques without advance notice or consent from Customer. SOCS may also use third party providers to conduct such internal analyses.

Network Information

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

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

• When Customer is using the Service;

• How Customer is using the Service, such as monitoring traffic patterns regarding websites visited, amount of data being sent or received, or other activity;

• The amount of data Customer is transmitting and receiving through the Service; and

• General information regarding the performance of the Provider Equipment installed on Customer’s property or at Customer’s premises, and its interaction with the rest of SOCS’s network.

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

• In response to an inquiry from Customer or an another Authorized User on Customer’s account regarding Customer or their use of the Service or problems Customer or they are experiencing using the Service;

• If SOCS has reason to believe Customer is using the Service in violation of Customer’s Service Agreement or any applicable statutes, rules, ordinances or regulations;

• If SOCS has reason to believe Customer use of the Service is negatively affecting other Customers; or

• When SOCS is required by law or legal process to do so, or when SOCS a good faith belief that SOCS is required by law or legal process to do so.

How is Personal Information used for marketing and advertising purposes?

SOCS will use Personal Information to send Customer marketing and advertising messages related to SOCS’s Service and website using Customer’s email address, postal address, or telephone number (for voice, texts, automated and pre-recorded calls).

SOCS may deliver a marketing or advertising message based on Customer visits to SOCS website, which will be general advertising or “Contextual Advertising,” which is advertising based on the subject matter or the content of the specific website page or subject matter. SOCS may also send Customer “First Party Advertising,” which is advertising or marketing that is customized or personalized based on a history of Customer’s use of our Services (possibly combined with information from our Facebook fan page or other social network platforms). First Party Advertising is based solely on a combination of information SOCS collects from Customer – not from Customer’s visits to other websites across the Internet. SOCS may use CPNI for its own First Party Advertising for products/services a Customer has already purchased. We will need your consent before using CPNI for marketing or advertising unrelated services. Customer may opt-out of First Party Advertising but not Contextual Advertising. No Personal Information is used to deliver Contextual Advertising; it automatically will appear based on the content or webpage Customer is viewing. And Customer may continue to receive general advertising if Customer opts-out of First Party Advertising, it will not be customized or personalized for Customer.

SOCS does not provide third party “Network Advertising,” which is advertising based on Customer’s overall Internet usage across different third party websites or online services. Multiple third party websites and online services are involved in this tailored or personalized advertising process, in essence a “network” of advertising providers. Because SOCS does not provide network ads, SOCS does not recognize the “Do Not Track” settings on various Internet browsers. SOCS does not engage or allow third parties to track you across the Internet and across time for advertising purposes.

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

If you receive advertising or marketing communications from one or more Affiliates, you must opt-out individually from each of the Affiliates from which you are receiving brand-specific marketing communications. Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable.

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

• To Our Affiliates. SOCS relies on various Affiliates in order to provide the Service to Customers. These are companies that are related to SOCS by common ownership or control. SOCS may share Personal Information and Non-Personal Information with any of its Affiliates for business, operational, promotional and/or marketing and advertising purposes.

• To Operational Service Providers: SOCS and its Affiliates contract with other companies and people to perform tasks or services on SOCS’s behalf and need to share Customer Personal Information to provide products or services to Customers. For example, SOCS may use a payment processing company to receive and process Customer’s ACH or credit card transactions for SOCS, or SOCS may contract with third parties to assist SOCS in optimizing SOCS’s network. Unless SOCS tells Customer differently, SOCS does not grant its Operational Service Providers any right to use the Personal Information SOCS shares with them beyond what is necessary to assist SOCS.

• For Business Transfers/Restructuring: SOCS may choose to buy or sell assets, or SOCS may sell assets or be sold. In these types of transactions, customer Personal Information is typically one of the business assets that would be disclosed and transferred. Also, if SOCS (or SOCS’s assets) are acquired, or SOCS goes out of business, enter bankruptcy, or go through some other change of control, including restructuring, re-organization or financing arrangements, Personal Information could be one of the assets disclosed, transferred to or acquired by a third party.

• For Protection of SOCS, and Our Affiliates, Employees, Operational Service Providers, Users and Customers and Public Safety: SOCS reserves the right to access, read, preserve, and disclose any Personal Information SOCS has access to if SOCS believes doing so will implement and/or enforce the Service Agreement, Website Terms of Use Agreement, Privacy Policy or any legal document; protect our Network(s), website(s), and company assets; protect the interests, rights, property, and/or safety of SOCS or Our Affiliates, employees and officers/directors, Operational Service Providers, Users and Customers, agents, third party licensors or suppliers, or the general public.

• When Required by Law or in Response to Legal Process: SOCS reserves the right to access, read, preserve, and disclose any Personal Information to which SOCS has access if SOCS is required by law or legal process to do so, or if SOCS has a good faith belief that SOCS is required by law or legal process to do so.

Is Customer Personal Information secure?

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

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

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

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

• Full name

• Username and password

• Email address

• Telephone number; and

• Billing and Service address

• Account and billing information

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

What third party disclosure choices do Customers have?

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

Will this Privacy Policy ever change?

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

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

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

If you have any questions or concerns regarding SOCS’s privacy practices and policies, please contact SOCS at 740-947-2409.