(Updated July 8, 2020)
As a subscriber to TDS TV services, including TDS TV+ provided by TDS, you are entitled under Section 631 of the Federal Communications Act of 1934 (the “Communications Act”) to know the following:
• the limitations imposed by the Communications Act upon operators in the collection and disclosure of personally identifiable information about subscribers;
• the nature of personally identifiable information we collect and the nature of the use of such information;
• the nature, frequency, and purpose of any disclosure of personally identifiable information which may be made and to whom;
• the period during which we maintain personally identifiable information;
• the process for gaining access to your personally identifiable information; and
• your rights under the Communications Act concerning personally identifiable information and its collection and disclosure.
In this notice, the terms “TDS,” “we,” “us,” or “our” refer to TDS Telecommunications LLC and its subsidiaries that provide TDS video services (“Video Service”). The term “you” refers to you as a subscriber to our Video Service.
The kind of information that the Communications Act and this notice apply to. The Communications Act applies to personally identifiable information that you have furnished to us, or that we have collected using our system, in connection with the provision of the Video Service. Personally identifiable information is information that identifies a particular person. It does not include aggregate data that does not identify a particular person or persons, or demographic information not connected to an identified individual or household, or non-personal information such as URL information, cookie data, IP address, network connection type, and device identifiers associated with set top boxes, modems, and routers, or other equipment.
The kind of personally identifiable information that TDS TV collects. The Communications Act authorizes us as a video service operator to use our Video Service facilities to collect personally identifiable information concerning any subscriber for the following purposes:
• in order to obtain information necessary, as further described in the privacy policy, to render our Video Service or other services to our subscribers; and
• to detect unauthorized reception of such services.
The Communications Act prohibits us from using our facilities to collect personally identifiable information concerning any subscriber for any purposes other than those listed above without the subscriber’s prior written or electronic consent.
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 generally include the following information: your name, addresses and telephone numbers; your date of birth; your Social Security Number; credit information and bank account or credit card numbers and other similar account information; e-mail addresses; your payment preferences; subscriber correspondence; or other demographic information, such as size of household.
We may also collect and maintain other information about your account, such as billing and payment history, maintenance and repairs, inquiry and technical support interaction, service options you have chosen, and other information related to installation and maintenance of your cable service, Internet PIN information, a security question and answer, employment information, customer correspondence and communications records, an emergency contact, records indicating the number of television sets and devices connected to our facilities, and the programming service options you have chosen.
Additionally, if you rent your residence, your landlord may need to provide permission prior to installing our IPTV facilities. IPTV (Internet Protocol Television) is television content that is delivered through technologies used for computer networks, instead of being delivered through traditional broadcast and cable formats.
When you use our interactive or other transactional television services, such as pay-per-use or video-on-demand (where available) services, TDS TV collects certain information on your use of these services. Most of this information is used to carry out a particular request you make using your remote control, set-top box or other equipment. This information may include information required to change your television channel, review listings in an electronic program guide, and pause or fast forward through certain programs, among other information. It may also include other information such as the time you actually use our services and the use of other features of our services. If you watch a pay-per-view program or purchase a product or service, for example, the system may collect certain personally identifiable information such as account and billing-related information related to the pay-per-view programs or other products or services ordered so that you may be properly billed for them.
Some of our advertisements may invite interactive or transactional follow-up from you. If you request products, services, features or information via such interactive advertisements, we collect and use the information generated by the request, including personally identifiable information when necessary, in order to carry out your request.
For TDV TV+ products, we collect information on how you use, watch, record, rate and interact with content and, if you use the voice activated remote control, audio data. If you download or use our mobile applications, we may collect, either through your mobile device or the application itself, your mobile device identifier, hardware model, operating system version or mobile network information (as well as any registration data you provide to us). We may also collect geolocation information, which may be used for operational and product- or service-related purposes, such as to customize information based on your location. If you do not want any data shared by our mobile applications, then please delete the mobile applications from your device.
We may also combine your personally identifiable information with personally identifiable information obtained from third parties for the purpose of creating enhanced databases or business records, and we may use these databases and these business records in marketing and other activities related to our Video Service and other services. We also maintain records of research concerning subscriber satisfaction and viewing or system-use habits, which are obtained from subscriber interviews and questionnaires.
We may also collect viewing data to determine which programs are most popular, how many people watch a program to its conclusion and whether people are watching commercials, as well as other audience measurement-focused information. All personally identifiable information is removed from this data. TDS, or our contractors or agents, may from time to time share this anonymous information with our advertisers, content providers, or other third parties working on our behalf such as audience measurement or market research firms.
Our audience measurement helps us and the program networks we carry decide on which programs and channels to carry and to improve our cable television services. We also use this information to provide you with a more personalized experience by directing advertisers to the channels that produce more sales as they consider, design, and evaluate advertising campaigns.
In addition to this privacy notice, we may provide additional notices to you regarding specific advertising or other initiatives. These notices will describe the initiatives in greater detail and may, as appropriate, contain information you can use to choose to participate, or not participate, in these initiatives.
For TDS TV+, if you integrate applications, websites, and services from entities other than TDS (“other-party services”) these may have their own terms and conditions of use and privacy policies, and such terms and conditions and policies shall apply to your use of these other-party services. If you integrate these other-party services to allow functionality such as including other-party services in searches or accessing other-party services via TDS TV+, you will be prompted to allow the other-party services to connect with your TDS TV+ service. If integrated, TDS will collect, process, and share data with the other-party services that you authorized. If you wish to stop the collection or sharing of information with other-party services, you need to disable the integration with such other-party services. TDS does not endorse and is not responsible or liable for the behavior, features, or content of any other-party service or for any transaction you may enter into with the provider of any such other-party service.
The ways that TDS TV uses personally identifiable information. We collect, maintain, and use personally identifiable information as permitted by the Communications Act. We use this information primarily to conduct business activities related to providing you with our Video Service and other services, and to help us detect theft of service. Generally speaking, we use personally identifiable information in connection with billing and collections, administration, surveys, marketing, service delivery and customization, maintenance and operations, and fraud prevention. We also use personally identifiable information to:
• install, operate, provide, improve, configure, maintain, and monitor the performance of our Video Service and other services;
• install, maintain and upgrade video services and the devices and software we use to provide them;
• confirm you are receiving the level(s) of service(s) you ordered and are being billed properly;
• identify you when changes are made to your account or services;
• inform you of new products or services that may be of interest to you;
• personalize the content we deliver (for example, TDS TV+ uses information on how you use, watch, record, rate, and interact with content to make programming recommendations);
• understand the use of, and identify improvements to, our services;
• analyze viewing habits;
• conduct industry or consumer surveys;
• detect unauthorized reception of our services;
• determine whether applicable policies and terms of service are being violated;
• configure Video Service-related devices;
• ensure our own compliance with the law;
• for tax and accounting purposes; and
• as otherwise necessary to provide the service;
• or as otherwise permitted or required by law.
Sometimes, we also obtain additional information from outside sources to supplement the information we collect from you. We might add information about you or your community available from third parties such as research consultants and marketing firms (such as the information that merchants use in delivering catalogues by mail, or census information about neighborhoods).
Disclosure of personally identifiable information to others. We consider the personally identifiable information contained in our business records to be confidential. The Communications Act authorizes us to disclose personally identifiable information concerning any subscriber for the following purposes if the disclosure is:
• necessary to render, or conduct a legitimate business activity related to, the Video Service or other services provided to the subscriber;
• required by law or legal process (as described below in this notice); 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 below in this notice).
The Communications 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.
We may disclose personally identifiable information as provided for in the Communications Act when it is necessary to render, or conduct a legitimate business activity related to the Video Service we provide to you. Generally, these disclosures involve billing and collections, administration, surveys, marketing, service delivery and customization, maintenance and operations, and fraud prevention. 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 our system and, where permitted by applicable law, provide any such non-personally identifiable or aggregate information that does not identify individuals to third parties. The frequency of any disclosure of personally identifiable information varies in accordance with our business needs and activities.
The Communications Act authorizes us to disclose limited personally identifiable information to others, such as charities, marketing organizations, or other businesses, for “mailing list” or other purposes. From time to time we may disclose your name and address for these purposes. Any “mailing list” and related disclosures that we may make are limited by the Communications Act to disclosures of subscriber names and addresses where the disclosures do not reveal, directly or indirectly, (i) the extent of any viewing or other use by the subscriber of the Video Service or other service provided by us; or (ii) the nature of any transaction made by the subscriber over any facilities used by us.
As provided for in the Communications Act, we may disclose personally identifiable information about you to our affiliates or to others who work for us, such as outside auditors, professional advisors, service providers and vendors, Installation, repair, and subscriber assistance subcontractors; entities providing services to us that we resell or license to you; billing and collection services; program guide distributors; software 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 Video Service or other services we provide to you. We also may be required by law or legal process to disclose certain personally identifiable information about you to lawyers and parties in connection with litigation and to law enforcement personnel. If we (or our parent company) enter into a merger, acquisition, or sale of all or a portion of our assets, in most instances our subscribers’ personally identifiable information will be one of the items transferred as part of the transaction.
Disclosures associated with other-party services are described above.
Limiting TDS TV’s use and disclosure of personally identifiable information. You have the right at any time to prohibit or limit disclosure of your personally identifiable information for “mailing list” purposes as described above in this notice by contacting us by telephone at 1-866-448-3788. If you have a joint account, a request by one party will apply to the entire account. If you have multiple accounts, your notice must separately identify each account covered by the request.
When TDS TV is required to disclose personally identifiable information by law. We make every reasonable effort to protect your privacy as described in this notice. Nevertheless, we may be required by law to disclose personally identifiable information about you without your consent and without notice in order to comply with a valid legal process such as a subpoena, court order, or search warrant.
We may also use or disclose personally identifiable information about you without your consent to protect the safety and security of our customers, employees, or property (including in emergency situations), to protect or defend the legal rights or property of TDS or its affiliates or their employees, agents and contractors (including enforcement of our rights under our terms of service, subscriber agreements and policies), to protect against fraud or for risk management purposes, if your account is referred to a collection agency or attorney, in court or elsewhere to comply with the law or legal process, such as a subpoena, and as otherwise permitted by law.
Protection of personally identifiable information. We take reasonable security safeguards to help protect against unauthorized access to personally identifiable information However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose personally identifiable information.
Maintaining personally identifiable information. We maintain personally identifiable information about you in our regular business records while you are a subscriber to our Video Service or other services. We also maintain this information for a period of time after you are no longer a subscriber 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.
We will not store personally identifiable information beyond what is necessary for business purposes, including for internal service evaluation and quality assurance purposes, except as otherwise required by law.
Examining personally identifiable information. You may examine your personally identifiable information that we collect and maintain in our regular business records. In most cases, the personally identifiable information contained in these records is billing and account information. If you wish to obtain a copy of the information, please provide your request in writing to TDS – Legal Dept., 525 Junction Road, Madison, WI 53717. All requests must include your TDS account number. We will mail the information to you at your current billing address. You will be permitted to request only records that contain personally identifiable information about you and no one else. We reserve the right to charge you for the cost of photocopying any documents you request. You will be provided a reasonable opportunity to correct errors if any of the personally identifiable information is inaccurate.
Recourse for violation of your privacy rights. If you believe that you have been aggrieved by any act of ours in violation of the Communications Act, you may enforce the limitations imposed on us by the Communications Act with respect to your personally identifiable information through a civil lawsuit brought in a United States District Court seeking damages, attorney’s fees, and litigation costs reasonably incurred. Other rights and remedies may be available to you under federal or other applicable laws, as well.
Changes to this notice. As required by the Communications Act, we will provide you with a copy of our subscriber privacy notice annually. We reserve the right to modify this Privacy Notice at any time. We encourage you to periodically review this notice to stay informed about TDS TV’s privacy practices.
