Privacy Policy and Your California Privacy Rights

 

COLUMBIA ENERGY LLC

Privacy Policy and Your California Privacy Rights

Updated and Effective date: July 11, 2018

Columbia Energy LLC ("Columbia Energy," "we," "our," or "us") understands that residential and business subscribers, visitors and users (collectively, "Subscribers," "you," or "your") care about how your personally identifiable information ("Personal Information"), as defined below, is collected, used and shared. Columbia Energy takes Subscribers’ privacy seriously. (We may use the term users separately from Subscribers, where appropriate.) Our Privacy Policy explains how we collect, use, disclose, and dispose of your Personal Information through the Columbia Energy website (the "Site") and any of our services, including broadband Internet access services, voice over IP services, \, and other related services purchased by you (collectively, the "Services"). This Privacy Policy http://columbiainet.com/content/privacy-policy together with Standard Customer Internet Agreement http://columbiainet.com/content/customer-internet-terms-agreement, the Internet Acceptable Use Policy http://columbiainet.com/content/internet-acceptable-use-policy and the Open Internet Policy http://columbiainet.com/content/open-internet-policy (collectively, "Service Agreements") govern your use of the Site and Services and our collection, use, disclosure, and disposal of your information.

By using or accessing our Site and Services in any manner, Subscriber acknowledges that Subscriber accepts the practices and policies outlined in this Privacy Policy. If you disagree with the way we collect, use, disclose, and dispose of Personal Information, do not use the Site or any of the Services.

Any capitalized terms not defined in this Privacy Policy will have the same meaning as defined in our Service Agreements.

Your California Privacy Rights

Generally, California residents are entitled by law to ask Columbia Energy for a notice identifying the categories of Personal Information that Columbia Energy shared with its 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 Columbia Energy meets certain exceptions in the law. This Privacy Policy and Site meet those exceptions. Therefore, if Subscriber resides in California and Subscriber has an established business relationship with Columbia Energy, Subscriber may request information about Columbia Energy’s opt-out and out-in policies of sharing Subscriber Personal Information with other companies (including our Affiliates) for their marketing purposes. Please send Subscriber’s written request via email or postal mail following the instructions below. Columbia Energy 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 Subscriber’s full name, street address, city, state and zip code.

• In an email request, Subscriber must state "Re: Your California Privacy Rights" in the subject line and send Subscriber email to billing@columbiainet.com.

• In a postal request, Subscriber must send a letter or post card to:

Columbia Energy LLC

2929 Melrose St.

Walla Walla, WA 99362

Attention: Your California Privacy Rights

General Information

Columbia Energy’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 Subscriber is not a U.S. citizen or does not reside in the U.S., Subscriber voluntarily consents to the collection, transfer, use, disclosure and retention of Subscriber Personal Information in the U.S. Subscriber also agrees to waive any claims that may arise under Subscriber’s own national laws.

When Subscriber uses the Site and Services, the Personal Information Subscriber 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 Columbia Energy’s objective to take reasonable measures to reduce the risk that unauthorized third parties will be able to intercept the information Subscriber sends and receives through the Site and Services, Columbia Energy cannot and does not make any guarantee that transmissions over the Internet are 100% secure or error-free.

Columbia Energy does not knowingly collect, solicit or use Personal Information from anyone under the age of 13. If Subscriber is under age 13, please do not attempt to register for the Services or send any Personal Information about yourself to Columbia Energy. If Columbia Energy learns that we have collected Personal Information from a child under the age of 13, we will delete that information as quickly as possible to the extent technically feasible. If you believe that your child under age 13 may have provided Columbia Energy Personal Information, please contact Columbia Energy at billing@columbiainet.com.

What Information does Columbia Energy collect and how does Columbia Energy use this Information?

Generally, Columbia Energy collects and uses Personal Information internally in connection with providing the Site and Services to Subscriber, including to personalize, evaluate and improve the Site and Services, to contact Subscriber, to respond to and fulfill Subscriber requests, and to analyze how Subscriber uses the Site and Services.

Columbia Energy collects and uses various types of information about Subscribers and Subscribers’ use of the Site and Services via various features and registration pages, Help Desk and call centers, postal mail, remote kiosks, the Columbia Energy Facebook Page or other social network platforms, or by other means. Such information is generally used and classified to help the customer understand more about their usage if requested.

Personal Information

Personal Information is the information Subscriber provides to Columbia Energy voluntarily or passively through Subscriber use of the Site and/or Services, and information which is directly associated with or reasonably linked to a specific person, computer or device. For example, we collect and use Personal Information through the registration process, when the equipment to provide the Service is installed, maintained or upgraded at Subscriber’s premises, and when Subscriber contacts Columbia Energy regarding the Site or Services. Through Subscriber account settings, Columbia Energy collects and uses Personal Information such as Subscriber name, email address, landline and/or wireless telephone number, postal address, billing address (if different) and billing information (such as credit/debit card account number or other financial account information), service address, and the nature of any of Subscriber devices or other property making use of the Services. Personal Information also includes Subscriber proprietary network information ("CPNI") which is collected and used to provide VoIP services to you. 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. Subscriber may be required to provide certain Personal Information to assist Columbia Energy in improving Subscriber’s Service or troubleshooting problems Subscriber is experiencing with the Site or Service, Subscriber computer or device, or otherwise to improve the quality of the Services.

Columbia Energy will communicate with Subscriber if Subscriber has provided Columbia Energy the means to do so such as submission of a Subscriber’s postal address, email address or phone number. Columbia Energy will mail, email, call or text Subscriber about Subscriber’s use of the Services or product improvements or upgrades, and other transactional information about Subscriber’s service.

Columbia Energy may also combine Personal Information with additional data obtained from Columbia Energy’s Facebook Pages or other social network platforms, its Affiliates, its Operational Service Providers (third party owned companies that provide or perform services on Columbia Energy’s behalf, to help serve Subscribers better and to perform functions in order to support Columbia Energy’s 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 Columbia Energy’s Site, Columbia Energy will collect various types of Non-Personal Information, such as information on Columbia Energy server logs from Subscriber’s browser or device, which may include Subscriber IP Address, unique device identifier, "cookie" information, the type of browser and/or device you are using to access the Services, and the page or feature Subscriber requested. (IP Address and device identifiers are traditionally classified as Non-Personal Information, unless Columbia Energy is required to do so otherwise under applicable law.) "Cookies" and "web beacons" are text file identifiers Columbia Energy transfers to Subscriber’s browser or device that allow Columbia Energy to recognize Subscriber’s browser or device and tell Columbia Energy how and when pages and features on the Columbia Energy Site are visited, by how many people, and other activity on the Site. Columbia Energy also use cookies to serve advertising to its visitors on third party websites. Subscribers can delete cookies used for advertising.

Subscribers can change the preferences on Subscriber’s browser or device to prevent or limit Subscriber’s device’s acceptance of cookies, web beacons or other similar technology, but this may prevent Subscribers from taking advantage of some of the features on the Columbia Energy Site, or accessing certain functions and conveniences. This Privacy Policy does not cover the use of cookies or other such tracking technology by any third parties, and Columbia Energy is not responsible for their privacy policies and practices.

Columbia Energy also uses Personal Information and Non-Personal Information to enhance the Columbia Energy Site and Services: such as how often visitors use a particular feature or activity; which products and services are most interesting to current and potential Subscribers; ways to make the Site useful and interesting to as many Subscribers as possible; and to enhance and refine Columbia Energy’s Services. Columbia Energy will continue to conduct analytics on Columbia Energy Site and Services performance. Subscribers may not opt-out of this use of cookies, Personal Information and Non-Personal Information.

Technology is improving every day and to improve Columbia Energy’s operations and functions Columbia Energy may introduce new technologies and monitoring techniques without advance notice or consent from Subscriber. Columbia Energy may also use third party providers to conduct such internal functions and analyses.

Network Information

Columbia Energy also collects and uses Columbia Energy Network Information, information about Subscriber access to, and use of, the Columbia Energy Network, which may or may not be directly associated with or reasonably linked to a specific person, computer or device. For example, Columbia Energy may collect use information about the performance of the our equipment installed on Subscriber property or at Subscriber premises, when Subscriber is using the Services, the various devices Subscriber is using to access the Services, the amount of data Subscriber is transmitting and receiving, the content of the data Subscriber are transmitting and receiving, the websites Subscriber is visiting, and any other information that is transmitted over the Columbia Energy Network. Columbia Energy may also aggregate Columbia Energy Network Information from multiple Subscribers and share such aggregated Non-Personal information about the overall performance of the Columbia Energy Services and Columbia Energy 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 Columbia Energy Network. Columbia Energy will not monitor the content of the websites viewed or email communications as part of Columbia Energy’s standard network management unless there is a complaint or an issue regarding the Services. Generally, Columbia Energy will monitor and preserve the following Columbia Energy Network Information:

• When Subscriber is using the Services;

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

• The amount of data Subscriber is transmitting and receiving through the Services; and

• General information regarding the performance of our equipment installed on Subscriber’s property or at Subscriber’s premises, and its interaction with the rest of the Columbia Energy Network.

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

• In response to an inquiry from Subscriber or an another Subscriber’s account regarding Subscriber or their use of the Services or problems Subscriber or they are experiencing using the Services;

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

• If Columbia Energy has reason to believe Subscriber use of the Service is negatively affecting other Subscribers; or

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

How is Personal Information used for marketing and advertising purposes?

Columbia Energy will use Personal Information to send Subscriber marketing and advertising messages related to Columbia Energy’s Services and Site using Subscriber’s email address, postal address, or telephone number (for voice, texts, and pre-recorded calls). Columbia Energy may deliver a marketing or advertising message based on Subscriber visits to the Columbia Energy Site, which is general advertising or "Contextual Advertising," defined as advertising based on the subject matter or the content of the specific website page or subject matter. Columbia Energy may also send Subscriber "First Party Advertising," which is advertising that is customized or personalized based on a history of Subscriber’s use of our Site or 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 Columbia Energy collects from Subscriber – not from Subscriber’s visits to other websites across the Internet. Columbia Energy will also use cookies for advertising purposes, however, cookies may not contain or link to any Personal Information.

Subscriber 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 Subscriber is viewing and thus is based on the context of that visit. Subscriber may continue to receive general advertising from other third parties if Subscriber opts-out of First Party Advertising from Columbia Energy.

Columbia Energy does not provide third party "Network Advertising," which is advertising based on Subscriber’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 Columbia Energy does not provide network ads, Columbia Energy does not recognize the "Do Not Track" settings on various Internet browsers. Columbia Energy does not engage or allow third party advertising networks to track you across the Internet and across time for advertising purposes. Columbia Energy does not engage or allow third parties to track you across the Internet and across time for advertising purposes.

Links to other websites or online services

The Columbia Energy Site and/or our 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 Columbia Energy and our Affiliates. The presence of a link does not constitute or imply Columbia Energy’s endorsement, recommendation, or sponsorship of the content, goods, services, business or privacy practices on such websites or online services. Columbia Energy encourages Subscribers to be aware and informed when Subscribers leave Columbia Energy’s Site and Columbia Energy’s Facebook Pages, or any other social networking platforms.

Will Columbia Energy share Subscriber Personal Information?

Subscriber’s Personal Information will only be disclosed to third parties (including Columbia Energy’s Affiliates) as listed in this Privacy Policy, or if Columbia Energy has received your consent at the time Columbia Energy will collect and use your Personal Information or prior to the disclosure of any Personal Information. Columbia Energy reserves the right to fully use, disclose and process any Non-Personal Information collected from Subscriber in any manner as well as any information Subscriber makes public via Columbia Energy’s Site or Services.

• Columbia Energy will not rent, sell or disclose Personal Information to anyone not related to Columbia Energy for marketing or promotional purposes, unless in connection with a potential or actual sale, merger or a corporate restructuring by or of Columbia Energy. (See "For Business Transfers" below for more information.) Columbia Energy will share Subscriber Personal Information with its Affiliates and with other third parties as described in this section for the following reasons:

To Our Affiliates. Columbia Energy relies on various Affiliates in order to provide the Services to Subscribers. Grizzly may share Personal Information and Non-Personal Information with any of its Affiliates for business, operational, promotional and/or Columbia Energy’s own marketing and advertising purposes.

To Operational Service Providers: Columbia Energy and its Affiliates contract with other companies and people to perform tasks or services on Columbia Energy’s behalf and need to share Subscriber Personal Information to provide products or services to Subscribers. For example, Columbia Energy may use an independent payment processing company to receive and process Subscriber’s ACH or credit/debit card transactions, or with third parties to assist Columbia Energy in optimizing the Columbia Energy Network. Unless Columbia Energy tells Subscriber differently, Columbia Energy does not grant its Operational Service Providers any right to use the Personal Information Columbia Energy shares with them beyond what is necessary to assist Columbia Energy.

To Facebook, Twitter and other Social Network Platforms: Via plug-ins on our Services

For Business Transfers/Restructuring: Columbia Energy may choose to buy or sell assets, or Columbia Energy may sell assets or be sold. In these types of transactions, Subscriber Personal Information is typically one of the business assets that would be disclosed and transferred. Also, if Columbia Energy (or Columbia Energy’s assets) are acquired, or Columbia Energy goes out of business, enters bankruptcy, or goes 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 Columbia Energy, and Our Affiliates, Employees, Operational Service Providers, Subscribers and Subscribers and Public Safety: Columbia Energy reserves the right to access, read, preserve, and disclose any Personal Information to implement and/or enforce the Service Agreements, protect the Columbia Energy Network, Site, and other company assets; protect the interests, rights, property, and/or safety of Columbia Energy or our Affiliates, employees and officers/directors, Operational Service Providers, Subscribers and Subscribers, agents, representatives, third party licensors or suppliers, or the general public.

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

Is Subscriber Personal Information secure?

Columbia Energy endeavors to protect the privacy of Subscriber’s account and other Personal Information Columbia Energy holds using reasonable administrative, technical and physical security measures. We dispose of your Personal Information in a secure manner related to how sensitive or confidential the Personal Information is. However, Columbia Energy cannot and does 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.

Subscriber’s account is protected by a password for Subscriber privacy and security. It is Subscriber’s responsibility to prevent unauthorized access to Subscriber’s account and Personal Information by selecting and protecting Subscriber password and/or other sign-on mechanism appropriately and limiting access to Subscriber computer, tablet or device and browser by signing off after Subscriber has finished accessing Subscriber’s account. Subscriber is required to notify us immediately if Subscriber’s password or account has been disclosed to a person whose name does not appear on Subscriber’s account, even if you have allowed such disclosure. Subscriber understands, acknowledges and agrees that Subscriber is solely responsible for any use of Columbia Energy Services via Subscriber’s Subscriber name and password.

Additionally, if Subscriber contacts Columbia Energy, Columbia Energy will ask Subscriber for verification of Subscriber’s identification and account. Columbia Energy will not send an email or text, nor should Subscriber 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 Subscriber receives an email or text from Columbia Energy requesting any such information or someone that claims they are with Columbia Energy or our Affiliates please contact our Privacy Administrator immediately billing@columbiainet.com

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

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

• Full name;

• Subscriber name and password;

• Postal Address;

• Email address;

• Telephone number;

• Billing and Service address; and

• Account and billing information.

By contacting Columbia Energy through any online account portal and/or via telephone, Columbia Energy may enable Subscribers to view and modify Subscriber account settings, and in some cases, edit or delete the Personal Information listed above. Current subscribers may not delete any Personal Information; you may only update or modify information. Former Subscribers may be able to delete Personal Information from active status depending on the services you subscribed to. When a Subscriber updates Personal Information, however, Columbia Energy may maintain a copy of the unrevised information in Columbia Energy’s records for internal security reasons and recordkeeping. Columbia Energy may also retain certain Personal Information indefinitely as required by Columbia Energy’s business practices, by law, and/or tax reporting purposes after Subscriber is no longer a Columbia Energy Subscriber.

Columbia Energy may use any aggregated data derived from or incorporating Subscriber’s Personal Information after Subscriber updates or deletes it, but not in a manner that would identify Subscriber personally. The information Subscriber can access, update, and delete may also change.

To prevent unauthorized access to your account and Personal Information, you may only access your account portal or account via a telephone Subscriber service representative after we have verified and authenticated your identity via your submission of a password, PIN, and /or a security question. Only then will you have the ability to modify or update your Personal Information (including access to CPNI, if applicable), and receive other account information either via telephone or online. If Subscriber has any questions about viewing or updating information Columbia Energy has on file, please contact Columbia Energy at billing@columbiainet.com.

What third party disclosure choices do Subscribers have?

Subscriber can always choose not to disclose Personal Information to Columbia Energy; however, certain Personal Information is necessary for Columbia Energy to provide the Services to Subscriber or to access certain parts of the Site. Subscribers may opt out of sharing Personal Information with our Affiliates only for marketing or advertising purposes, but not for business or operational purposes.

Subscriber may opt out of email marketing and advertising from Columbia Energy or its Affiliates using the "Unsubscribe" mechanism in each email. Before Columbia Energy sends Subscriber a text for any reason, or sends Subscriber a pre-recorded call that contains advertising or marketing information, Columbia Energy will secure Subscriber’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 Subscriber’s prior express consent in writing, unless they are sent to a wireless device. Subscriber 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 Services. Subscriber may opt out of receiving text messages any time by replying "STOP" or "UNSUBSCRIBE" to the text message. Subscriber may opt out of receiving pre-recorded calls by the opt-out instructions in the call. However, Subscriber will continue to receive calls related to debt-collection and Subscriber’s current service. Subscriber 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.

Subscriber may not opt out of Columbia Energy’s use of cookies or other similar technology, or use of Subscriber’s Personal Information and Non-Personal Information for Columbia Energy’s internal analytics used to monitor activity on Columbia Energy’s Site, measure Columbia Energy Services’ performance, or to operate and protect the Columbia Energy Network.

Will this Privacy Policy ever change?

Yes, because Columbia Energy is constantly working to improve and introduce new features or products in our Services, we will need to update this Privacy Policy from time to time as our business practices change and service offerings increase, and/or there are changes in local, state or federal laws. Additionally, Columbia Energy will also make stylistic, organizational and/or grammatical changes to present Columbia Energy privacy practices in a Subscriber friendly easy to read manner. Columbia Energy will alert Subscribers to any such changes by placing a notice on http://columbiainet.com with the effective date of the revised Privacy Policy, and/or by sending Subscribers an email, or by some other means to the extent required by law. Subscribers are always responsible for reading and understanding all notices posted on Columbia Energy’s Site, whether their contact information is updated or not. Subscriber’s continued use of the Services or Site after notice of any changes have been provided will indicate Subscriber’s acceptance of such changes, except where further steps are required by applicable law.

Use of Subscriber’s Personal Information is primarily governed by the Privacy Policy in effect at the time Subscriber subscribed to the Service or visited the Columbia Energy Site. If Columbia Energy elects to use or to disclose Personal Information in a manner that is materially different than that stated in the Privacy Policy in effect at the time you subscribed to the Services or visited the Columbia Energy Site, Columbia Energy will provide Subscriber 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 Columbia Energy’s privacy practices and policies, please contact Columbia Energy at billing@columbiainet.com.

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