Privacy Policy

Protecting privacy is not a new endeavor for Farmers Telephone Company. FTC has a long-standing tradition of recognizing and protecting the privacy of customers who use its telecommunications services. FTC maintains strict customer information privacy policies and uses state of the art technologies to safeguard customer information and communications from unauthorized intrusions.

FTC recognizes that the growth of Internet services has created additional privacy concerns, particularly for consumers. Online privacy concerns focus primarily on the protection of “customer identifiable” information which an individual or other customer reasonably expects to be kept private. As the term suggests, “customer identifiable” information is information that, when associated with an individual identifies that individual, for example, a customer’s name, address, telephone number, and e-mail address.

Some Internet users may also wish to know who can learn about what they do on the Internet, even when that online behavior is not directly linked to any information that identifies an individual. For example, advertisers may observe whether visitors to a web site see or respond to online advertising without knowing who those visitors are.

It is common practice and often a necessity for companies, governments, or other organizations to collect customer identifiable information in order to conduct business and offer services. For example, a telecommunications provider may collect customer identifiable information, such as name, address, telephone number, and a variety of other information in the course of billing and providing services to a customer.

Some activities on the Internet follow very familiar patterns. Consumers signing up for an Internet access service, for example, are usually asked to provide name, address, telephone number and credit card and other information that is typical when the consumer orders a product or service. Similarly, business web sites may ask visitors to supply information about themselves, particularly when information, services or merchandise are requested, but often simply to be able to better target WIN’s services to the customer’s interests and requirements.

FTC HAS PUT IN PLACE THE FOLLOWING PRIVACY POLICY

This policy covers FTC and its subsidiaries, including Heartland Net. FTC will continue to protect customer information derived from its local, long distance, Internet, video, and wireless services consistent with federal laws and with federal regulations issued by the Federal Communications Commission.

In order to be consistent with this policy, FTC expects each of its Internet customers to be familiar with and to have read and understood all of the information described in the Acceptable User Policy.

HOW FTC PROTECTS YOUR PRIVACY ONLINE

Collection and Use: FTC will collect and use customer identifiable information for billing purposes, to provide and change service, to anticipate and resolve problems with your service, or to create and inform you of products and services that better meet your needs. This means that FTC may use your customer identifiable information, in conjunction with information available from other sources, to market new services to you that FTC thinks will be of interest to you, but FTC will not disclose your customer identifiable information to third parties who want to market products to you.

When you access the Internet, the computers that host web sites you visit (web servers) automatically receive some anonymous information. This “usage data” may include a record of which pages a web browser has visited. FTC servers receive usage data when customers visit westianet.com sites, and when FTC Internet customers visit other sites as well. FTC may use usage data to provide advertising about goods and services that may be of interest to FTC customers, or to provide customized features and services. FTC will not use information about your activities on the Internet together with any information that identifies you without your consent.

DISCLOSURE

FTC will not sell, trade, or disclose to third parties any customer identifiable information derived from the registration for or use of a FTC Internet service including customer names and addresses — without the consent of the customer (except as required by subpoena, search warrant, or other legal process or in the case of imminent physical harm to the customer or others).

When FTC uses other agents, contractors or companies to perform services on its behalf, FTC will ensure that it protects your customer identifiable information consistent with this Policy. If FTC includes your name and any other customer identifiable information in a directory that FTC creates from information received as an ISP, or internet service provider, FTC will give you the opportunity to have your information excluded from that directory. Business directories that FTC creates may, however, contain information obtained from other sources.

SECURITY

FTC has implemented technology and security features and strict policy guidelines to safeguard the privacy of your customer identifiable information from unauthorized access or improper use, and FTC will continue to enhance FTC’s security procedures as new technology becomes available.

E-MAIL CONTENTS

FTC will not read or disclose to third parties private e-mail communications that are transmitted using FTC services except as required to operate the service or as otherwise authorized by law.

IMPROPER CONDUCT

FTC may also use customer identifiable information to investigate and help prevent potentially unlawful activity or activity that threatens the network or otherwise violates the customer agreement for that service.

ACCOUNT INFORMATION

FTC honors requests from customers to review all customer identifiable information maintained in reasonably retrievable form, which currently consists of your name, address, e-mail address, telephone number and/or billing information, and will correct any such information which may be inaccurate. Customers may verify that appropriate corrections have been made.

ADDITIONAL PRIVACY PROTECTION FOR CHILDREN USING THE INTERNET

FTC joins the industry in recognizing that children, including young teens, may not be able to make informed choices about personal information requested online. Accordingly, FTC does not target children or teenagers (younger than eighteen years of age) for collection of information online. FTC does not solicit or collect customer identifiable information targeted at children and teenagers under eighteen and does not allow anyone else to do so on a FTC web site. In addition, the editorial content of FTC web sites designed for children will not knowingly promote or link to any third party web site that collects customer identifiable information unless that Web site publishes a privacy policy that is easily accessible.

In addition, on all of its online services and FTC web sites, FTC will encourage children to seek the consent of their parents before providing any information about themselves or their households to anyone on the Internet.

FTC encourages parents to take an active role to protect the privacy and security of their children and to prevent the inappropriate use of information about their children. FTC supports the development of technologies that help parents to control the collection and use of personal information from children who use online services in their households.

Finally, FTC is compliant with the PROTECT Our Children Act. The PROTECT Our Children Act is a federal statute which imposes certain reporting and retention requirements for ISPs (and other companies which provide electronic communications services or remote computing service) and who have actual knowledge of activities involving child pornography or the sexual exploitation of children. Service providers are required to report actual knowledge of certain criminal behavior to the National Center for Missing and Exploited Children (NCMEC) tip line but are not required to monitor users or to affirmatively seek facts or circumstances that would trigger a report.

If you would like more information on how to protect your children while they are online, visit the Federal Trade Commission’s OnGuardOnline website at https://www.onquardonline.gov.

CUSTOMER PROPRIETARY NETWORK INFORMATION (CPNI) POLICY

FTC knows the importance of personal privacy to FTC’s customers. FTC keeps all account information strictly confidential to the fullest extent possible and uses industry-accepted technology to safeguard customer data. Federal law concerning telecommunications companies regulates the use of account information to selectively market specific products and services to specific customers.

TO WHAT KIND OF INFORMATION IS FTC REFERRING?

This information, legally referred to as Customer Proprietary Network Information (CPNI), includes data such as which long distance carrier you have chosen, what calling features you use and which calling plans, if any, to which you may be subscribed.

WHO USES THIS INFORMATION AND IS IT PROTECTED?

Only FTC can see or use this information. It is never released to outside companies. You have the right, and FTC has the duty under federal law, to protect the confidentiality of this type of information.

WHAT DO I NEED TO DO?

No action on your part is necessary unless you wish to restrict FTC’s use of this type of information to contact you for the purpose of tailoring FTC service offerings to your individual needs. Should you wish to restrict use of your CPNI, or if you have any concerns about the FTC privacy policy or its implementation, please call us at 712-379-3001 or send an e-mail to support@heartland.net with your request within 30 days of receipt of this policy. Restricting CPNI may make you ineligible to receive information from WIN about new products and services, promotions and packaged offerings.

HOW DOES THIS AFFECT SERVICES I RECEIVE?

Whatever you decide will not affect the provision of any services to which you subscribe. Your approval or denial for use of CPNI will remain valid until you notify FTC otherwise. Again, FTC only uses your account information to market other telecommunications services and products FTC offers and no action is required on your part unless you wish to restrict FTC’s use of your CPNI.