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California Consumer Privacy

Effective Date: January 1, 2021

This California Consumer Privacy Notice (“Notice”) applies to CoxCom, LLC and its communication related affiliates, (“Cox,” “us,” “we, “our”) and “Consumers” as defined by the California Consumer Privacy Act (together with related regulations the“CCPA”) and should be read along with our other privacy notices found on www.cox.com.  In the event of a conflict between any other Cox policy, statement or notice and this Notice, this Notice will prevail as to California Consumers’ rights under the CCPA. There are other companies in the Cox corporate family that have their own California privacy notices and consumer rights programs. You will need to consult their policies and make requests to them separately.  

To make this easier to read, we have abbreviated or summarized terms from the CCPA, but a full copy of the CCPA is available at Title 1.81.5. of the California Civil Code, California Consumer Privacy Act of 2018 section 1798.100 - 1798.199. Capitalized terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.

Sections 1 and 2 of this Notice covers our Collection, use, disclosure, and Sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, for the twelve months preceding January 1, 2021, .and will be updated annually.  Our practices in calendar year 2021 may change and if we make material changes we will provide notice about the new collection or use.  Sections 3 and 4 of this Notice describe the rights California Consumers have and includes notices to Californians required by other laws. 

We may from time-to-time update information in this Notice regarding our data practices and your rights, modify our methods for responding to your requests, or supplement our responses to your requests as required to reflect updates to the law or guidance by the California Attorney General on how to interpret it.

This CCPA Notice does not apply to information collected from job applicants, current and former employees and contractors of Cox, and persons with whom we interact with in their capacity of representing another business. If we collect information about you in any of these contexts, this Notice will not be applicable to you.

This Notice contains a comprehensive explanation of our data practices and Consumer rights under the CCPA, but you can find a shorter explanation and FAQs here.

You can click on the following links to navigate to the different sections in this Notice.

1.     PI We Collect

a. Categories
b. Sources
c. Purposes

2.     Sharing of PI

3.     Your California Privacy Rights

a. Right to Know
b. Do Not Sell
    i.  Exercising DNS Rights
    ii. Managing Cookie Preferences
c. Right to Delete
d. Non-Discrimination
f.  Exercising Your CCPA Rights
g. Limitations on Your Rights

4.     Additional California Notices

a. Third Party Marketing
b. Online Privacy Practices
     i.  Tracking and Targeting
     ii. California Minors

5.    Contact Us

  1. PI We Collect

a. Categories

The table below provides the categories of PI we Collect about California Consumers, examples of the PI we Collect, and the types of recipients we share PI with, in connection with our Business, based on our 2020 practices.

For purposes of the table below customers services providers include call center vendors, field services technicians, security providers, and other similar types of vendors.

Category of PI Examples of PI Categories of Recipients with whom PI is Shared
1. Identifiers  This may include but is not limited to: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.

Advertising networks, data analytics providers, credit and collection agencies, e-signature services, marketing services companies, data brokers, customer services providers, and other Service Providers.

Other third parties such as media measurement companies and TV programmers.

2. Personal Records  This may include but is not limited to: telephone number, employment details, credit or debit card number, or other financial information.

Data analytics providers, credit reporting agencies, e-signature services, marketing services companies, credit and collection agencies, customer services providers, and other Service Providers.

3. Customer Characteristics  This may include but is not limited to: age, veteran status, accommodations information, gender and interests.

Advertising networks, marketing services companies, data analytics providers, and other Service Providers.

4. Customer Account Details / Commercial Information  This may include but is not limited to: products or services purchased, obtained, or considered, other purchasing or consuming histories or tendencies.

Data analytics providers, marketing services companies, collection agencies, customer services providers, and other Service Providers.

5. Services Activity Information   This may include but is not limited to: information regarding your interactions with web sites, applications, or advertisements, service-related data such as the amount of Internet data used by your household, cable and telephone service activity, TV viewership activity, and home security.

Advertising networks, data analytics providers, marketing services companies, customer services providers like call center vendors, and other Service Providers.

Other third parties such as media measurement companies and TV programmers.

6. Geolocation Data   This may include but is not limited to: market location or movements.

Data analytics providers, advertising networks, customer services providers, marketing services companies, and other Service Providers.

7. Sensory Data   This may include but is not limited to: audio recordings of customer care and sales calls, electronic, visual, or similar information.

Data analytics providers, marketing services companies, and other Service Providers.

8. Professional or Employment Information This may include but is not limited to: professional, education, or employment-related information.

Data analytics providers, marketing services companies, and other Service Providers.

9. Inferences from PI Collected
This may include but is not limited to: creating a profile about a Consumer reflecting the Consumer’s characteristics, interests, and preferences.

Data analytics providers, marketing services companies, and other Service Providers.

In addition, each of the above referenced categories of PI may be shared with government agencies, other third parties as required by law or compelled by legal process, to the Consumer or other parties at the Consumer’s request, and to assignees as part of a merger or asset sale.

Further, we may deidentify or aggregate your PI, and as permitted by applicable law, we do not treat De-identified or Aggregate Consumer Information as PI. Similarly, as permitted by the CCPA, we may not treat publicly available data as PI.

b. Sources

Based on our 2020 practices, we collect PI directly from you, your devices or browser, vendors that assist us in providing our services and running our internal business operations, data analytics providers, advertising networks, operating systems, suppliers, public databases, social media platforms, data append services, other companies in the Cox family of businesses, and other data providers.  

c. Purposes

Based on or 2020 practices, we collect PI for the following Business Purposes:

  • Providing our services, including maintaining and servicing your accounts, verifying your information, billing and processing payments, marketing, selling advertising, analytics services, and similar functions and services;
  • Detecting security incidents and protecting against malicious, deceptive, or illegal activity;
  • Troubleshooting our services to identify and repair issues;
  • Internal research and development;
  • Quality and safety assurance, and improving, upgrading, and enhancing our products and services;
  • Processing and managing interactions and transactions for our products and services; and,

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2. Sharing of PI

Based on our 2020 practices, we may share your PI with our Service Providers that help us complete the Business Purposes for which we Collected the PI, as detailed in the chart above. In addition, if you direct us to share PI with another party, that is not a Sale and we may make such a disclosure to honor your request. In addition, we may share PI for the Additional Business Purposes explained above.  

Based on our 2020 practices, we may also share your Identifiers and Services Activity Information for commercial purposes, such as for TV viewership for advertisers. This sharing of PI may be considered a Sale under the CCPA’s broad definition of “Sale,” even though it does not include the Sale of your PI with your name, address, e-mail, phone number or other contact information. (“Pseudonymous Data Transfers”). We offer you the ability to opt-out of these disclosures as set forth in the “Do Not Sell” portion of Section 3 below. We share PI as part of our Pseudonymous Data Transfers to third parties such as media measurement companies and TV programmers and permit them to use for their own purposes.   

We do not believe that third party cookies that facilitate online advertising or other purposes with our online services, which themselves Collect and share PI, are a Sale of your PI by us to them under CCPA, however you can learn how to exercise choices regarding those third party technologies and Online Advertising here. In addition, we provide you with additional information about your choices regarding third party technologies, including through our cookie preference center as well as third party tools, in the “Do Not Sell” portion of Section 3 below. 

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3. Your California Privacy Rights

Your California privacy rights are described in this section. California Consumers  have the right to exercise these rights via an authorized agent who meets the agency and verification requirements of the CCPA. Agents should go here to make requests.

To protect your privacy and comply with our obligations under the CCPA, requests you submit are subject to an identity and residency verification process as permitted or required by the CCPA. We will not fulfill your CCPA “Right to Know” or “Right to Delete” requests unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI (“Verifiable Consumer Request”). Please follow the instructions at our CCPA page here and respond to any follow up inquires we may make.  For Consumers that cannot be verified through their Cox account credentials, we require verification through a third party service associated with a credit bureau that will ask you questions based on your consumer history in order provide us a sufficient degree of certainty that you are who you say you are. Otherwise, to protect your privacy, we will reject your request and refer you to this Notice for information on our data practices generally, and if you made a deletion request remind you how to opt-out of Sales.

We will make commercially reasonable efforts to identify Consumer PI that we Collect, use, and store in response to your California Consumer privacy rights requests.  Some of the PI we Collect is voluminous, difficult to present to you, or generally not helpful, so we may provide a list of that PI and give you the opportunity to elect whether you want the rest or not.  If you are a Cox customer or former customer, some of your PI is accessible to you through our self-service tools located in My Account or is otherwise readily available to you without the need to make a Right to Know request. For instance:

  • Your account number, services subscribed to, plan details, discounts and purchases are available on your Cox bill;
  • Your household Internet data usage are available in your My Account;
  • Your payment methods are found in the billing information in your My Account;
  • Your Cox email is available in your email account; and
  • Notification preferences and privacy preferences are located in your My Account
  • Personal Information is also available in Cox’s apps, such as the Cox App, Cox Panoramic Wi-Fi app, etc.

We will not send copies of PI available in our self-service tools. 

While we will not charge a fee for routine requests, we may charge a reasonable fee, or refuse to act upon a request, if your request is unfounded (e.g., unwarranted, unsupported, seeks irrelevant data, etc.) or unreasonably repetitive or burdensome. For example:

  • We collect “Services Activity Information,” which includes your interactions with our services, such as the amount of Internet usage, video viewership records, telephone call detail records, etc. to serve you and improve our services. We treat Services Activity Information as PI that you can access through your account. To obtain your Services Activity Information, you will need to access it through our self-service options in your account.
  • In addition, “Telemetry/Network Data” is network and application data Cox has in connection with, for example, measuring service and network quality, capacity, and device health. Telemetry/Network Data is necessary to operate our networks, but so voluminous or irrelevant to an individual that Cox does not treat this as PI.

If we determine that your request warrants a fee, or we refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept the incurring of fees before we will charge you for responding to your request.

We have no obligation to keep PI longer than we need it, or reidentify it, to respond to Consumer requests. This helps us practice data minimization, which we consider to be a privacy best practice consistent with our mission to respect our customers. If, however, you make a CCPA request we will retain your PI provided to us to make your CCPA request for our record keeping purposes.

If we cannot comply with a request, we will explain the reasons in our response.  If you have any questions or concerns about Cox’s California privacy policies and practices, you can submit questions or comments to californiaprivacy@cox.com.  

Your California CCPA Consumer privacy rights are as follows:

a. Right to Know

You have the right to send us a request, no more than twice in a twelve-month period, for the following information for the period that is 12 months prior to the request date (please note that PI is retained for various time periods so we may not have PI in all categories going back 12 month):

  • The categories of PI we have Collected about you.
  • The categories of sources from which we Collected your PI.
  • The Business or Commercial Purposes for Collecting or Selling your PI.
  • The categories of Third Parties to whom we have shared your PI.The specific pieces of PI we have Collected about you.
  • A list of the categories of PI disclosed for a Business Purpose in the prior 12 months, and for each category of such PI the categories of recipients.
  • A list of the categories of PI Sold about you in the prior 12 months, and for each category of such PI the categories of recipients.  

To protect you and comply with the CCPA, we will not provide copies of sensitive data such as credit card and social security numbers. If you have an account with us, you must utilize your My Account to obtain a copy of your PI related to your account and usage data that we make available to you on a self-serve basis, and this will not be included in a response to a Right to Know.  Similarly, as explained above, you must access your email account to access emails and your billing account to access billing data, and that PI will not be included in response to a Right to Know request. If you do not have an account and would like to make a request, or seek copies of PI not available on a self-serve basis, please go here or call us at 1-800-699-0885 (service hours are Monday-Friday, 8am - 5pm Pacific Time, except holidays).  

b. Do Not Sell

i. Exercising DNS Rights

You have the right to direct us to not Sell your PI. As discussed above, the CCPA’s definition of a “Sale” is both unique and broadly worded and may capture disclosures beyond what you might think of as a Sale.  Our approach to your CCPA “Do Not Sell” opt-out rights are explained below.  As the law evolves, we may change our approach, but in the interest of giving you control over your PI we have developed Consumer data control programs even where we do not think the law requires.

As discussed above, we may engage in Pseudonymous Data Transfers when we share household TV viewership data with advertisers and others, but we never include your name, address, e-mail, phone number or other contact information. We offer the ability to opt out of these disclosures in your My Account preferences. We treat this sharing of TV viewership data as a Sale under the CCPA’s broad definition of a “Sale,” and accordingly a “Do Not Sell” request will opt you out of Pseudonymous Data Transfers.  You can also exercise your CCPA “Do Not Sell” rights here.

ii. Managing Cookie Preferences

We do not believe that third party cookies that facilitate online advertising or other activities in connection with our online services, which themselves Collect and share PI, are a Sale by us of your PI under CCPA and, accordingly, a “Do Not Sell” request to us will not affect the Collection activities by third party cookies.  However, we provide Californians who use our online services a way to manage their cookie preferences based on categories of cookies through our management tool available here. You will need to do this on each browser that you use to access our websites and clearing cookies on your browser(s) may disable your preference settings. More information on how to exercise choices regarding third party cookies and interest-based advertising is available here.

In addition, some third-party cookie operators that collect PI in connection with our online services for advertising, analytics and other purposes offer you the ability to opt-out of their own downstream Sales. Please visit here to opt-out of the Sale of PI by these participating third parties. This is a third-party program and we are not responsible for its effectiveness. You must opt out on every device and browser you use in order to effectuate your “Do Not Sell” requests from these parties. However, opting out does not mean you will stop seeing ads and you may continue to still see interest-based ads. To learn more about interest-based advertising and additional opt-out choices related to it, please visit here.

We do not have actual knowledge of the age of Consumers under 16 and do not knowingly link PI with Consumers under age 16.   

c. Right to Delete

You may request that we delete PI collected directly from you unless we need it for permitted purposes, such as to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, to protect against fraud, or for other legitimate internal Business Purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. We will not delete your PI that we are permitted to retain, for so long as the permitted retention purpose remains, after which we will delete the PI. In some situations, we may deidentify or aggregate data in lieu of deletion., To make a request, go here or call us at 1-800-699-0885 (service hours are Monday-Friday, 8-5 Pacific Time, except holidays). As with a Right to Know request, to protect you, we will require you (or your agent) to be verified before honoring your deletion requests.  

Many Consumers, especially those that we currently serve, don’t really want us to delete all of their PI. Indeed, we can’t delete all of your data if you are a customer. However, we appreciate that you may want to limit our use and disclosure beyond what is needed to provide those services. You may choose to limit use of your PI by making selections in the Privacy Preference Center by visiting your My Account here. In addition, deletion for former customers is limited by exceptions permitted under the CCPA. Anyone who receives commercial emails from us may opt-out of future commercial emails by following the unsubscribe directions in the footer of those emails. You can exercise choices regarding cookie preferences as noted in the “Do Not Sell” section above.

d. Non-Discrimination

We will not discriminate against you in a manner prohibited by the CCPA because you exercised your CCPA rights.  

e. Exercising Your CCPA Rights

We encourage Consumers, including current customers, to make CCPA requests via our privacy portal at www.cox.com/ccpa. Copies of PI available by the self-serve methods described above must be accessed using such methods.

We verify customers via their account, or for non-account holders through a third-party service that uses information about Consumer’s history to ask questions the answers to which will help us determine if you are who you say you are. We do this to protect your privacy and security and comply with the CCPA’s requirements. If you are not a Cox customer, you do not have to create a service account with Cox to make a request, but you will have to set up identity verification credentials to exercise your rights. We will use PI provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses unless you also gave it to us for another purpose

Authorized agents of Consumers can make a request here, which will also be subject to verification. 

f. Limitation on Your Rights

Notwithstanding anything to the contrary, we may collect, use and disclose your PI as required or permitted by applicable law. In addition, we will not honor any of your requests to the extent doing so would infringe upon our rights or any other person or party’s rights or conflict with applicable law.

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4. Additional California Notices

In addition to CCPA rights, Californians are entitled to certain other notices, including:

a. Third Party Marketing

We will not share personal information as defined by California Civil Code § 1798.83 (“Shine the Light” law or “STL”) with third parties, outside of the Cox family of companies, for their direct marketing purposes without your consent. You can make a request to receive details on our sharing of such personal information with members of the Cox family of companies for their direct marketing purposes within the prior 12 months, by sending an email to californiaprivacy@cox.com and indicating “Shine the Light” in the subject line or body of your email request. You can also make a request by mail to the address below: 

CoxCom LLC6205-B Peachtree Dunwoody Road
Atlanta, GA 30328
Attn:  Privacy Operations – 15th Floor
 

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

b. Online Privacy Practices

For more information on our online practices and your California rights specific to our online services see our Online Privacy Policy.  Without limitation, Californians that visit our online services and seek or acquire goods, services, money or credit for personal, family or household purposes are entitled to the following notices of their rights:

i. Online Tracking and Targeting

When you visit our online services, we and third parties may use tracking technologies to collect usage information based on your device for a variety of purposes, including serving you advertising, based on you having visited our services or your activities across time and third-party locations.  Some browsers may enable you to turn on or off a so-called “Do Not Track” signal.  Because there is no industry consensus on what these signals should mean and how they should operate, we do not look for or respond to “Do Not Track” signals.  For more information on tracking and targeting and your choices regarding these practices, see our Online Privacy Policy.  Consumers can also exercise preferences regarding cookies by following the instructions here.

ii. California Minors

Although our online service(s) are intended for an audience over the age of majority, any California residents under the age of eighteen (18) who have registered to use our online services, and who posted content or information on the online service, can request removal by contacting us at californiaprivacy@cox.com detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that we do not control.

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5. Contact Us

For more information on your California privacy rights contact us at 1-800-699-0885 (service hours are Monday-Friday, 8-5 Pacific Time, except holidays) or email us at californiaprivacy@cox.com. You may also visit our Privacy Preference Center accessible via your My Account or our Consumer Rights Request page or write to us at:

Cox Communications
6205-B Peachtree Dunwoody Road
Atlanta, GA 30328

Attn:  Privacy Operations – 15th Floor

 

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