At HiLight we value the trust our customers place in us, and we honor that trust through our commitment to protect your privacy. We know our customers care about how and when we collect, use, maintain, and share information about them and the procedures we have in place to protect their information.

5.1 Types of Information Collected

(a) Information You Provide To Us
We collect the information that you provide to us when you create an account with us, when you use online account tools, when you call or email us or otherwise communicate with us. This information includes

• Name
• Business entity name (if a commercial account)
• Contact information (such as billing address, service address, email address, phone numbers)
• Payment information (such as credit card or bank account information)
• Credit application information (such as social security number, driver’s license number, or other government issued identifier)
• Account access authentication information (such as password, security question answers)
• Information on custom settings or preferences
• Customer communications and other communications records (such as records of calls with customer service representatives)

(b) Information Collected When You Use the Services

• Account number
• Billing, payment, and deposit history
• Maintenance information
• The types of service you subscribe to
• The device identifiers and network addresses of equipment used with your account
• Records indicating the number and types of devices connected to our network
• Technical information about your service-related devices, including customization settings and preferences
• Network traffic data
• Information about your use of the services and their features, including internet or online information such as web addresses and other activity data to render internet service

(c) Information Provided by Third Parties

We also obtain data and information about you from third parties. For example, when you request new or additional services from us, we may obtain credit information from credit reporting agencies. Additionally, if you rent your residence, we may have a record of whether landlord permission was required prior to installing our services as well as your landlord’s name and address. 

5.2 How the Information Collected is Used

The information we collect is used to provide and improve services and our network. This information is also used to communicate with you and create measurement and analytics reports. We use information that identifies you personally when authenticating your account or when communicating with you. We also use information that is de-identified (i.e., cannot be connected back to you personally) or aggregated (i.e., data that is grouped together and not tied to any specific individual). We also use the information we collect to deliver and personalize our communications with you. For example, we may use the contact information you provide to inform you of Service updates or the status of a service request or outages, to invite you to participate in a survey, to collect amounts you owe, or in connection with other activities related to the Service(s). We will provide you with service-related announcements, such as a pricing change, a change in operating policies, a service appointment, or new features of one or more of the Service(s) you receive from us through emails, texts, calls, HiLight provided equipment, and other communications methods.

To Provide and Improve the Services

We use the information we collect to conduct business related activities related to providing you with the services. These uses include:

• Establishing your account
• Measuring credit and payment risk
• Billing and invoicing
• Authenticating access to your account
• Account administration
• Service delivery
• Maintenance and operations, including management of the network and devices supporting our service and our systems 
• Technical support
• Hardware and software upgrades for devices and systems
• Understanding the use of our service
•  Improving our services
•  Identifying new products and services
• Communicating with you
• Marketing and advertising 
• Detecting the unauthorized reception, use, or abuse of the services and to protect our customers from fraudulent, abusive, or unlawful use of, or subscription to, the services
• Analyzing customer usage data, such as the amount of bandwidth that is being used, the peak times of usage, or the types of services that are being used
• collecting fees and charges
• protecting our rights, our personnel, and our property
• complying with applicable law

5.3 How Your Information is Protected

We follow industry-standard practices to secure the information we collect to prevent the unauthorized access, use, or disclosure of information about our customers. These security practices include technical, administrative, and physical safeguards. Although we take the responsibility of safeguarding your information seriously, we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose your information.

5.4 How Long Your Information is Retained

HiLight maintains information that personally identifies you in our regular business records while you subscribe to one or more of our services. We also maintain service information for a minimum of three years after you no longer subscribe to a service in order to comply with the City of Hillsboro’s state-approved record retention schedule in accordance with OAR Chapter 166, Division 200.  After the retention period, we will destroy, de-identify, or anonymize the information according to our internal policies and procedures.

5.5 Sharing and Disclosures of Information

(a) In order to provide and support the services, we sometimes use other providers to undertake that work on our behalf to:

• Process payment transactions
• Carry out fraud and credit checks
• Run surveys
• Collect fees and charges 
• Provide customer service, marketing, infrastructure, and information technology services
• Perform auditing and accounting
• Provide professional advice and consulting
• Assist with maintenance and operations
• Assist with security incident verification and response and fraud prevention. 

When we use another organization, we still control your personal information, and we have strict controls in place to make sure it’s properly protected. For example, we require these service providers to treat the information we share with them as confidential and to use it only for the purpose of providing the services for which they have been engaged.

(b) Voice Service Disclosures

If you subscribe to our voice service, we may disclose information about you to others in connection with features and services such as Caller ID, 911/E911, and directory services as follows

• We may transmit your name and/or telephone number to be displayed on a Caller ID device unless you have elected to block such information. Please note that Caller ID blocking may not prevent the display of your name and/or telephone number when you dial certain business or emergency numbers, 911, 900 numbers, or toll-free 800 numbers and similar numbers.
• We may provide your name, address, and telephone number to public safety authorities and their vendors for inclusion in E911 databases and records
• We may publish and distribute, or cause to be published and distributed, telephone directories in print, on the internet, or on disks. Those telephone directories may include subscriber names, addresses, and telephone numbers, without restriction to their use
• We may also make subscribers names, addresses, and telephone numbers available through directory assistance operators.
• Once our subscribers’ names, addresses and telephone numbers appear in telephone directories or directory assistance services, they may be sorted, packaged, repackaged, and made available again in different formats by anyone

We take reasonable precautions to ensure that non-published and unlisted numbers are not included in telephone directories or directory assistance services, but we cannot guarantee that errors will never occur.

(c) Legal Disclosures

There are times when we may be required by law or legal process to disclose information about you to lawyers and parties in connection with litigation and to law enforcement personnel. These disclosures may be made without consent or notice in compliance with the terms of valid legal processes such as a subpoena, court order, or search warrant. We may also disclose information that personally identifies you as permitted by law when:

• It is necessary to protect our customers, employees, or property
• In emergency situations
• Enforce our rights under our terms of service and policies

(d) Customer Proprietary Network Information (CPNI)

CPNI is the information that is generated when you use internet or VoIP (voice) service. Examples of CPNI include call details (such as the numbers you’re calling, the numbers calling you, and call times and dates) and your rate plan and features. Under Section 222 of the Communications Act of 1934, broadband providers who offer VoIP have a duty to protect the confidentiality of CPNI. Additionally, the Federal Communications Commission (FCC) rules provide additional privacy protections specific to voice services. HiLight is allowed to use CPNI for billing, providing services, 911 calls, and to comply with court-ordered information requests. We are permitted to disclose CPNI information to the customer whose data it is and to persons our customers have authorized to receive this information. We will require authentication, such as a password, for any customer-initiated telephone contact where call detail information is being requested. HiLight does not share any CPNI information for marketing purposes.

5.6 How You Can Access and Correct Your Information

It is important that your account records contain accurate information. By providing adequate personal identification, you may review your account information and inspect personally identifiable information during office hours. Customers shall have the right to correct an inaccurate information in their account records.

5.7 Updates to the Privacy Policy

HiLight will provide you with a copy of the current privacy policy at the time we enter into an agreement to provide any internet or voice service to you. We may modify this policy at any time. You can view the most current version of this policy on our website. If we make material changes to the privacy policy, we will provide you with at least 30 days’ notice. If you continue to use the service following notice of the changes, we will deem that to be your acceptance of and consent to the changes in the revised privacy policy.