UPDATED JANUARY 2023
Your privacy is important to Mid-Hudson Cable. We value the trust you place in us when you subscribe to Mid-Hudson Cable branded cable video, Internet, and phone services (collectively, the ‘Mid-Hudson Cable Services’), We take seriously the responsibility of protecting your privacy and the information we collect about you.
This Annual Privacy Notice describes the types of information we collect; how we use and share that information; and the choices you have regarding such use and sharing. It also describes the legal limitations imposed on our collection, use and sharing of information that personally identifies you; how long we maintain that information; how you may access, review and correct that information; and your rights under federal law and this Annual Privacy Notice concerning such information.
The commitments in this Annual Privacy Notice reflect our core business objective of providing you with the most innovative and superior products and services as possible while, at the same time, offering you choices about how we use information about you to achieve that objective.
We commit to:
• Communicate our privacy practices in a manner that is easily accessible and clearly describes your choices;
• Offer you choices about how we may use your information for our own marketing purposes;
• Not sell your personally identifiable information to anyone for any purpose – this, includes our customers’ web browsing history, call detail records, and viewing activity;
• Secure your information through the use of reasonable security measures; and
WHEN THE ANNUAL PRIVACY NOTICE APPLIES
Depending upon the Mid-Hudson Cable products and services to which you subscribe, parts of this Annual Privacy Notice may not apply to you. For example, if you only subscribe to Mid-Hudson Cable Internet, the sections of this Annual Privacy Notice that discuss Mid-Hudson Cable Voice information will not apply to you. To help clarify some of our more general statements, we provide real-world examples throughout the Annual Privacy Notice of how we collect and use information. These are only examples and may not cover every situation. If you have questions, please contact us.
• when you download applications or make purchases from other companies while using our Internet or wireless services;
• when you log-in and access video content provided by a third party through your Mid-Hudson Cable-issued device;
• through any other products, services, websites, or applications, including your interactions with online video and other third-party content services, even if you access them through the Mid-Hudson Cable Platform; and
• by devices that are not Mid-Hudson Cable devices, e.g., a tablet, smartphone, or other device that enables you to access the Mid-Hudson Cable products or services, or through a smart television where the manufacturer has directly enabled information gathering capabilities.
You should read the privacy policies for these other products, services, websites, applications and devices to understand their privacy practices; those privacy policies will apply to those third parties’ collection of your information, even if access to such content or use of such products or devices requires you to be a Mid-Hudson Cable subscriber; for example, some of the premium streaming services available online that require you to authenticate your subscription using your Mid-Hudson Cable username and password.
HOW WE COLLECT INFORMATION
In order to provide you with our products and services and to keep you informed, we collect a variety of information about you when you interact with us or use our products, services, websites and applications. This information is needed for us to efficiently provide our services to you on a cost-effective basis and to tailor our products and services to best meet your needs and interests. For example, in order to provide timely and effective customer service, we keep track of when you called, what the issue was and what is the best way to get in contact with you.
If you are a Mid-Hudson Cable customer and you allow others to access and/or use your accounts, products or services, we will collect information about those users, as well. We may also collect information about you from third parties.
Information You Provide to Us Directly or When You Create an Account
We collect information you provide to us when you establish as a customer and when you contact us or otherwise communicate with us, such as:
• contact information (e.g., name, address, email address, and phone number) usernames, passwords, images, voiceprints, and other authenticating information, including other biometric information, associated with a Mid-Hudson Cable account;
• information about the types of services to which you subscribe, orders you place or downloads you make through a Mid-Hudson Cable product or service, the service options you have chosen, and any customized setting you have created;
• information about your payment methods, such as your payment card number or bank account information;
• information related to a credit application for a product or service or to protect against fraud, which may include your Social Security number, driver’s license number, or other government issued identifier;
• information you provide when you enter contests or respond to customer surveys; and
• information we keep in our records when you correspond or otherwise communicate with us, including through our call centers, online chat sessions, and through social media.
Information We Collect Automatically and Through Your Use of the Products, Services, Websites and Apps
When you use the Mid-Hudson Cable Services, we automatically collect information, such as:
• information from any device you use when you interact with us, including but not limited to the device identifiers, the number, types, and status of devices connected to our network, network addresses, operating system, and technical configurations of the equipment used with our services, products, websites and applications;
• network traffic data;
• performance and support data; and
• information about your use and the operation of Mid-Hudson Cable products, services, websites, applications, and their features.
The information we collect will depend upon the Mid-Hudson Cable Services to which you subscribe. We limit the use and sharing of such information as described in this Annual Privacy Notice and as required by law. For example, we may collect usage information about:
• the channels, programs, and advertisements to which your device was tuned when you subscribe to our video service in order to provide you video content (‘Video Usage Information”);
• the websites you visit when you are using the Mid-Hudson Cable Internet or WiFi services, in order to provide the service and connect you to the other sites and services you request (“Internet Usage Information”);
• call records, including the phone numbers that you call and that call you, and the times and dates of those calls, the number of text messages sent and received, when you subscribe to our phone service (“Call Detail Information”); and
If you subscribe to or use services that require us to transfer or store communications such as a Mid-Hudson Cable voice product that includes a voicemail service, it will be necessary for us to collect the content of those communications to provide you with the service you have requested because it is required in order for the services to function.
We also collect device information, including your IP address and information about your browser, operating system, and platform type. The collection of this information, including IP addresses and the referring websites, is required in order for us to provide Internet service and for users to communicate with each other and with websites on the Internet.
When you access our network, we may collect general location information, such as the city or zip code that correlates with the license of your device IP address, or more precise geolocation data that indicates where you are at a specific point in time.
When you first visit or use any mobile application that collects precise geolocation information to access a Mid-Hudson Cable Service to which you subscribe, we will request permission to collect and use such information. You can prohibit the collection of this information through your device’s settings (see “Your Choices”) but it may limit certain functions and features of the application.
Information Obtained from Third Parties
We may collect information from third parties for purposes related to delivering the Mid-Hudson Cable Services to you. This includes information to verity information you have provided and from credit reporting agencies to determine your creditworthiness, credit score, and credit usage.
If you rent your residence, we may have a record of whether landlord permission was required prior to installing our cable facilities as well as your landlord’s name and address.
We receive information from content providers and other platform providers when you use your Mid-Hudson Cable account to authenticate your use of Mid-Hudson Cable Services through that providers platform or device. For example, a Mid-Hudson Cable subscriber to HBO will have access to the HBOMAX app on their mobile device. When using that app, the Mid-Hudson Cable subscriber will be required to provide their Mid-Hudson Cable user information to HBO, which then provides that information to Mid-Hudson Cable to confirm that the HBOMAX user is a subscriber.
We also obtain additional information from outside sources, such as research consultants and marketing firms. We may collect commercially available demographic information about you or your community available from third parties, such as age, gender, and preferred language. We may also collect commercially available interest data, such as whether you like to travel or are a sports enthusiast.
HOW AND WHEN WE USE INFORMATION, INCLUDING FOR ADVERTISING
First and foremost, we use the information we collect to provide you with reliable, high-quality products and services. We also use the information we collect to communicate with you, make improvements to our products and services, investigate theft and other illegal activities, and personalize your experience, as described below. This may involve linking and combining information about you from across the Mid-Hudson Cable platforms of products and services, as well as from third parties (‘Combined Information”).
To Provide and Improve our Services
We use the information we collect to:
• properly deliver, maintain and improve our products, services, websites and applications;
• fulfill requests for new service or changes to your account or the products and services you already receive;
• provide you with technical support and high-quality customer service, including through the use of recorded or monitored communications between you and our customer service agents;
• create and administer a Mid-Hudson Cable account, including activating your service, billing, invoicing, and debt collection activities;
• authenticate or otherwise provide you access to your Mid-Hudson Cable products and services; provide updates, upgrades, repairs or replacements for any of our service-related devices or software used in providing or receiving services;
• manage and configure our device(s), system(s) and network(s);
• understand how the service is being used, including through the creation of
operational and marketing reports based on de-identified and/or aggregated service usage information;
• inform you of additional products and services that may be of interest to you;
• protect the security of the system, prevent fraud, detect unauthorized reception, use, and abuse of any Mid-Hudson Cable product, service, website or application, and to enforce any Mid-Hudson Cable policy or applicable terms of service;
• protect our rights, our personnel, our property, and the safety of others;
• maintain our accounting, tax and other records; and
• comply with applicable federal and state laws and regulations, as well as for the general administration of our business.
To Communicate with You
We use the information we collect to deliver and personalize our communications with you. For example, if you use an interactive or transactional service, e.g., responding to a survey or ordering a pay-per-view event, we will use that information and information from your account to send you billing information, as well as recommendations for additional Mid-Hudson Cable products or services that may be of interest to you and to provide you with a more personalized experience. We may use the information to remind you of a service appointment, to follow up with you after a service request, and to send you important service-related notices and announcements.
We may send you promotional communications for products and services that may be of interest to you through the mail, over our cable system, by phone or SMS, or online. Some of these communications may be directed to you because of the Mid-Hudson Cable services to which you subscribe or your interactions on the Mid-Hudson Cable platform, and some may be directed to you because of your general geographic location. For example, if we are launching a new service in limited areas, only residents of that particular area will receive that promotional communication. This is often called “zone” advertising.
To Create Business and Marketing Reports
We use the information we collect to create business and marketing reports (the “Reports”) to provide insights into what products and services our customers are using, how long they are using our products and services, how some of our services are accessed, and what additional products and services may be of interest to our customers. In the video context, for example, these Reports contain information such as channel tuning, the time a channel is changed, when a Mid-Hudson Cable set-top box is “on” or ‘off, whether a program or commercial was watched to its conclusion or skipped, and whether the content was accessed during its regular airing schedule, or through a Mid-Hudson Cable website app, or a third party’s platform. We may create similar reports in the phone and broadband contexts that measure and analyze service usage information, such as the peak times of usage, the amount of bandwidth used, and the amount – but not the content – of data stored on our systems.
We use these Reports for our own internal purposes, such as improving our products and services, determining what content to provide our customers, measuring the effectiveness of our marketing and advertising, and other research and analytics.
We use some of the information we collect to make the marketing and advertising you see on the Mid-Hudson Cable Platform more relevant to you, as well as to market the Mid-Hudson Cable products and services on other websites and platforms. Many of our marketing and advertising activities use information that does not personally identify you, such as your ZIP Code, your IP address, advertiser IDs and other persistent identifiers that are not directly linked to any identifiable information. Some of our marketing and advertising activities, however, do include the use of information that personally identifies you. For example, we use your postal and email address to deliver marketing and advertising to you. We may also use Combined Information to create marketing and advertising campaigns. For information about how to limit the use of information for these purposes, see the “Your Choices” section below.
Addressable Advertising on our Cable System
Some of the advertisements you see on cable channels are placed by us. Some of those advertisements are placed in particular shows or channels; others are shown in particular geographic areas. Some of our cable advertisements will ask for your permission to take certain actions, like mail you information or allow the advertiser to contact you
Online Advertising and Customization
We may place “cookies” in your browser that contain information about you or your account when you set up a personalized service or customize your settings and preferences on our websites or mobile applications. Cookies enable us to help diagnose problems with our services, control the display of ads, track usage patterns, gather demographic information, analyze trends, conduct research, and otherwise administer the Mid-Hudson Cable services. We do not store sensitive information such as your password, e-mail address or credit card number in cookies.
We use third party service providers to place advertisements for the Mid-Hudson Cable services on the Internet. These providers use standard tracking technologies used by most major websites and mobile applications to collect non-personal information about your visits to our websites and mobile applications, as well as your interaction with our products and services. These providers may also use information about your visits to other sites to send interest-based advertisements for other products and services and to gauge the effectiveness of advertisements. We do not permit these third parties to collect or use information that personally identifies you, such as your name, address, phone number or email address.
WHEN AND WITH WHOM WE SHARE
We share information with others when it is necessary to provide you with Mid-Hudson Cable Services to which you subscribe, and others in the limited
circumstances described below. We do not sell or otherwise share information that personally identifies our customers, including their Internet Usage Information, Video Usage Information, or Call Detail Information, to third parties for those third parties’ own use, such as marketing or advertising of their own products and services.
While we have no plans to do so, if we ever changed this business practice, we would provide customers with advance notice and obtain their express consent.
Account Holders and Other Authorized Users
We may disclose any information about a customer’s account and use of a service or feature to the primary account owner after appropriate authentication.
The primary account owner may also authorize other users to access information on the account, which may include information about the primary account owners use of the relevant service.
Mid-Hudson Cable/Mid-Hudson Cable Related Businesses
We may share information about you with other Mid-Hudson Cable and Mid-Hudson Cable related companies in order to provide the services to which you
subscribe, or to make your Mid-Hudson Cable experience more streamlined, such as through combining account information into a single location for easier access. We may also share information about you with these related companies for their own marketing purposes when we have any necessary consent required to do so.
We may disclose your information to third-party service providers who perform business activities and functions on our behalf to support our interactions with you such as billing and collections, payment processing, analytics and research, marketing, service delivery and customization, maintenance and operations, and fraud prevention. These third-party service providers are authorized to use your personal information only as necessary to provide these services on our behalf.
Governmental Entities or Pursuant to Valid Legal Process
If you subscribe to any Mid-Hudson Cable Services, we may be required by law to disclose information about you, including information that personally identifies you, your use of our services, and the content of your communications, to governmental entities upon receipt of valid legal process. These disclosures may be made with or without your consent and with or without notice, in compliance with the law, including the terms of process.
If you subscribe to Mid-Hudson Cable video service and a governmental entity is seeking information about your selection of video programming, the Cable Act
requires the governmental entity to obtain a court order. In the proceeding relevant to the issuance of the court order, the government must provide clear and convincing evidence that you are reasonably suspected of engaging in criminal activity and that the video records sought would be material evidence in the prosecution of the case. You are to be afforded the opportunity to appear and contest the governmental entity’s claims in such proceeding.
We may also disclose personally identifiable information about you, without your consent, to protect our Customers, employees, or property; in emergency situations; to enforce our rights in court or elsewhere, or directly with you, for violations of service terms, conditions or policies; and/or as otherwise required by law.
We do not sell or share information that personally identifies our customers with third parties for their own marketing or advertising purposes. If you subscribe to our telephone service, your name, address and/or telephone number may be transmitted via Caller ID, published and distributed in affiliated or unaffiliated
telephone directories, and available through affiliated or unaffiliated directory assistance operators. We take reasonable precautions to ensure that non-published and non-listed numbers are not included in the telephone directories or directory assistance services, although we cannot guarantee that errors will never occur. Please note that Caller ID blocking may not prevent the display of your name and/or telephone number when you dial certain business numbers, 911, 900 numbers or toll-free 800, 855, 844, 866, 877 or 888 numbers
Some of the advertisements we display may invite interactive or transactional follow-up from you. When you interact and provide your consent, we may share your contact information with such advertiser for the purpose of fulfilling your request. If we enter into a merger, acquisition, or sale of all or a portion of our assets, we may transfer information about you, including information that personally identifies you, as part of the transaction.
WHAT CHOICES YOU HAVE TO CONTROL THE USE OF INFORMATION BY MID-HUDSON CABLE
You have many choices in controlling how we use and share your information for marketing and advertising purposes. For instance, you can always choose
whether to receive promotional emails or text messages.
You may visit unsubscribe mhcable.com to manage your privacy preferences, including:
• to be added to our ‘Do Not Call,’ ‘Do Not Email,’ ‘Do Not Mail’ or ‘Do Not Knock’ list, which will limit the marketing and advertising messages you receive about
Mid-Hudson Cable products and services; and
• to limit our use of Video Usage Information, Combined Information, or our business and marketing reports to direct addressable advertisements or interest-based advertisements to you as further described in the preference center.
Some of the preferences will only apply when you subscribe to Mid-Hudson Cable services and may require additional account information. If you make changes to your contact information or get a new account, you will need to review and update your privacy preferences.
If you do not have access to Internet service, you may call us at the number provided on your monthly bill statement to be added to any of these lists.
Please note that even if you choose to limit the use of information or communications for marketing and advertising purposes, you will still receive general advertising and zone advertising, in addition to service-related messages.
When you initiate an interaction with one of our representatives, such as a phone call or a chat, we may ask for your oral consent for use of your CPNI for the purpose of providing you with an offer for other products or services, such as the Mid-Hudson Cable video service. If you consent, we may use your CPNI for the duration of such interaction to offer you those additional products and services.
If you subscribe to the Mid-Hudson Cable Voice®, we would like to use the CPNI information we have on file to provide you with information about products and services or special promotions for other communications-related products and services to which you do not already subscribe. You have the right to restrict this use of CPNI. If you deny or restrict your approval for us to use your CPNI, you will experience no effect, now or in the future, on how we provide any services to which you subscribe. We will wait at least thirty days from the date we first provide notice to you, as a subscriber of the Mid-Hudson Cable Voice® service, before we use your CPNI for this purpose. During that time and at any time after, you may opt-out of our use of your CPNI for these marketing purposes by calling us at the number provided on your monthly billing statement or visiting our Privacy Preference Page.
HOW WE PROTECT YOUR INFORMATION
We take our responsibility to secure the information we collect and maintain seriously. We use reasonable security, including technical, physical and administrative controls, to secure the information we collect and maintain. However, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose Mid-Hudson Cable information.
You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorized interception of your personal information. You are responsible for the security of your information that you transmit to us or view, download, or otherwise access when using unencrypted, public or otherwise unsecured networks. For more information on things you can do to help protect the privacy of your own information, visit – www.Mhcable.com/security
WHAT YOUR RIGHTS AND OUR LIMITATIONS ARE UNDER FEDERAL LAWS
The Cable Act and Personally Identifiable Information
Section 631 of the federal Cable Act gives a subscriber to the Mid-Hudson Cable Cable Act Services the right to know about the personally identifiable information we collect and how we use it; under what conditions and circumstances and the types of persons and entities to whom we may disclose personally identifiable information;
how long we maintain personally identifiable information; the limitation on our ability to collect and disclose personally identifiable information collected from the cable system;
and a subscribers rights under the Cable Act concerning personally identifiable
information and its collection and disclosure.
Personally identifiable information is information that identifies a particular person; it does not include de-identified or aggregate data that does not identify a particular person or persons.
The Cable Act permits us to use the cable system(s) to collect personally identifiable information about our subscribers when it is necessary to render the Mid-Hudson Cable Cable Act Services or other services we provide and to detect unauthorized reception or use of the Mid-Hudson Cable Act Services. We may use the cable system to collect personally identifiable information about a subscriber for additional purposes with a subscribers prior written or electronic consent.
When a government entity is seeking information about your selection of video programming, you have additional rights as described in the
Governmental Entities or Pursuant to Valid Legal Process’ subsection of ‘When We Share Information with others:
If you subscribe to a Mid-Hudson Cable service that is governed by the Cable Act, we will maintain information that personally identifies you and that is associated with your use of such service for as long as necessary for the purpose for which the information was collected, which may be as long as the duration of your subscription and after you have terminated your subscription, in some instances. For example, we may keep information that personally identifies you as necessary to comply with laws governing our business, such as tax and accounting requirements that require record retention, to satisfy pending requests for access by a subscriber to his/her information or pursuant to a court order, or to respond to your inquiries or otherwise communicate with you after you have terminated your subscription. We will destroy or de-identify such information when ii is no longer needed for such purposes.
If you believe that you have been aggrieved by any act of ours in violation of law, we encourage you to contact us in order to resolve your question or concern. You may also enforce the limitations imposed on us by the Cable Act with respect to your personally identifiable information through a civil lawsuit in federal district court seeking damages, attorneys’ fees, and litigation costs. other rights and remedies may be available to you under federal or other applicable laws as well. Your Mid-Hudson Cable Residential Services Agreement contains your agreement that, to the extent permitted by law, any claims under the Cable Act may be enforced in arbitration.
The Communications Act and CPNI
Section 222 of the Communications Act provides additional privacy protections for information about the quantity, technical configuration, type, destination, location, and amount of your use of the Mid-Hudson Cable telecommunications services, and information about your Mid-Hudson Cable phone service that is contained on your bill. This information, when linked to an identifiable customer of such service, is known as customer proprietary network information or ‘CPNI.’ CPNI does not include a customer’s name, address, and telephone number, which is defined by the Communications Act as ‘subscriber list information’ and is not subject to the CPNI protections. However, that information is considered ‘personally identifiable information,’ and is subject to the Cable Act protections described above.
HOW TO ACCESS AND CORRECT THE INFORMATION IN OUR RECORDS
We strive to keep our records accurate. If any of your information changes, please notify us immediately so we can update our records.
If you subscribe to a service subject to the federal Cable Acts requirements and you would like to see the personally identifiable information we maintain in our business records, please send a written request to our office or call us at the number provided on your monthly billing statement and we will make an appointment for you to visit during normal business hours. You will only be permitted to examine records that contain personally identifiable information about your account and no other account. If your review reveals an error in our records, we will correct it. We reserve the right to charge you for the cost of retrieving and photocopying any documents that you request. You may also be able to access certain information about you or your account by contacting one of our customer service representatives at 518-943-6600, or by logging in to your online account.
If you make a written request for a copy of your CPNI, we will disclose the relevant information we have to you at the address we have for your account, or to any person authorized by you, if we reasonably believe the request is valid. For telephone and online access to your CPNI such as outbound call detail records, we require that you first authenticate your identity using a password established using our online system. We generally do not provide our customers with records of calls received, records that are only in our archives, other records that we do not furnish as part of a telephone bill, webbrowsing history, IP address logs or any other information that we do not create or maintain in the ordinary course of business unless there is a court order or similar legal process. Please understand that we may have no control over information appearing in directory lists or provided by directory assistance services which we do not own.
HOW TO CONTACT US WITH QUESTIONS ABOUT HOW THIS ANNUAL PRIVACY NOTICE APPLIES
Questions about Mid-Hudson Cable’s privacy protections and practices should be sent to:
Mid-Hudson Cablevision, Inc.
Attn: Privacy and Cybersecurity
200 Jefferson Hgts
Catskill, New York 12414
You may also contact our customer service office at 518-943-6600.
Effective: January 30, 2023