KUPA`A KEY-Z PRIVACY NOTICE
 
We at your Oceanic Time Warner Cable ("Operator," "we" or "us") are providing
this Notice to inform you of our practices regarding personally identifiable
information that may be collected through your membership in the Kupa'a Key-Z
customer loyalty program ("Key-Z," "we" or "us").
This Notice pertains to personally identifiable information about you that
you have furnished to the Key-Z customer loyalty program, or that Operator has
collected, in connection with your participation in Key-Z. Personally
identifiable information does not include aggregate data that does not identify
you.
The policies described in this Notice will also apply to third parties with
whom Key-Z must work to fulfill the program requirements.
Three areas are covered by this Notice:
1. The Collection and Use of Personally Identifiable Information
2. The Nature, Frequency, and Purpose of any disclosure that may be made of such
information;
3. The Period of Time such information will be maintained;
1.Collection and Use of Personally Identifiable Information
In order that Key-Z can provide service to you and operate efficiently, Key-Z
collects the following types of information about you that may constitute
personally identifiable information: your name, home email and work addresses,
telephone numbers, social security number, and credit and credit card
information. Depending on the services Key-Z provides to you, our records also
may include information on billing and payment. We may also keep records of
research concerning subscriber satisfaction with our services, which are
obtained from subscriber interviews and questionnaires. We also maintain Program
Members correspondence (via email or otherwise) Finally, Key-Z may sometimes
obtain from third parties publicly available information about our Program
Members.
The information described in the preceding paragraph is used for purposes
such as the following: to make sure Program Members records are properly
maintained; to send you pertinent information about Key-Z's services; to
maintain or improve the quality of Key-Z's services; to answer questions from
Program Members (i.e., for troubleshooting); to ensure compliance with relevant
law and contractual provisions; to market cable or other services or products
that you may be interested in; and for tax and accounting purposes.
Agreement, to the collection of personally identifiable information as
described in this paragraph.
Key-Z may also collect personally identifiable information without Program
Members' consent if it is necessary to provide services to Program Members.
Key-Z also may collect the following types of information that may constitute
personally identifiable information: registration and account information,
including your name, address, telephone number, screen names and email
address(es), means of subscription, billing and payment (including credit card)
information, and complaint and service history; The information collected by
Key-Z in connection with your participation in the program may be used in
connection with the provision and maintenance relevant to Key-Z and to fulfill
transactions that you request, to personalize or improve participation in
program experience, or as otherwise necessary in the course of their businesses.
Our Key-Z Program Partners may also use this information to provide advertising
and other offers for goods and services to you, subject to the marketing
preferences you may select when using their Services.
2. The nature, frequency, and purpose of any disclosure that may be made
of such information;
Personally identifiable information that Key-Z maintains related to its Program
Members will be disclosed by Key-Z without the prior written or electronic
consent of Key-Z participants only if: (1) it is necessary to render, or conduct
a legitimate business related to, the services that are provided to you; (2)
such disclosure is required by law or legal process as described below; or (3)
for mailing lists as described below. The types of persons to whom information
about you may be disclosed by Key-Z in the course of providing Key-Z program
participation to you include the employees of Pacific Wave Marketing and Oceanic
Time Warner Cable and its related legal entities, agents, sales representatives,
accountants, billing and collection services and credit reporting agencies,
consumer and market research firms, and authorized representatives of
governmental bodies. Also upon reasonable request, personally identifiable
information is disclosed to persons or entities with an equity interest in legal
entities related to Key-Z when they have a legal right to inspect our books and
records. If you wish to have us remove you from our mailing list, please notify
us in writing at the main office of your local Operator.
In addition to any disclosures permitted in the first paragraph of this Section
2, our Program Partners may also disclose, pursuant to the consent you granted
in your Participation Agreement, the personally identifiable information
described in Section 1 in connection with the provision of services to you, in
order to fulfill transactions that you request, to comply with criminal or civil
legal process (including as described in Section 3 of this Notice), and as
otherwise necessary in the ordinary course of their businesses. For example, our
Program Partners may disclose your personally identifiable information routinely
to their employees, agents and contractors to maintain, market, provide, and
audit the Key-Z program; to outside auditors to check their records; to
attorneys and accountants as necessary to render services; and to merchants from
whom you make purchases. The frequency of such disclosures varies according to
business needs. The names and addresses of Program Members to our Program
Partners may also be disclosed to selected companies in order to provide you
direct mail product and service offers, subject to the marketing preferences you
may select when participating in the program. In disclosing name and address
information for such purposes, our Program Partners may combine these lists with
publicly available information (such as census and household information), or
segment them (i.e., create separate sublists) based on such publicly available
information or on other information.
In your Program Participation Agreement, you have agreed that Key-Z and our
Program Partners may also disclose any information in its possession to protect
its rights, property and/or operations, or where circumstances suggest that
individual or public safety is in peril.
3.Time Period That We Retain Personally Identifiable Information
Key-Z and its Program Partners maintain personally identifiable information
about Program Members for as long as it is necessary for business purposes. This
period of time lasts as long as you are a Program Member and up to fifteen
additional years so that we and our Program Partners can comply with tax and
accounting requirements. When information is no longer necessary for these
purposes, we destroy the information unless there is a legitimate outstanding
request or order to inspect the information.
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