Personal Information

This policy applies to personally identifiable information (“personal information”) that we directly associate with a specific entity or person (for example, name, social security number, addresses, telephone numbers and call records). Not included in personal information is “aggregate” or “anonymous” information, neither of which is associated with a specific entity or person.

Collection of Personal Information

We collect personal information about you when you use our services or otherwise interact with us including visiting our web site. This information includes personal information you provide when you sign up for and use our services, when you e-mail, call, or otherwise communicate with us. For example, we may collect credit personal contact, and billing information when you sign up for services or purchase other products or services. We may also collect personal information when you call and or e-mail our customer service representatives, enter information on our web site, pay for service, or submit survey responses. When your computer or other communication device accesses or web browsers, use our web sites, we automatically receive certain information, such as your browser type, IP address, and date and time. We may also obtain personal information about you from other sources. For example, we may obtain updated address information from our vendors or shippers. We may also purchase personal information (for example, e-mail lists, postal mail lists, marketing and demographic data) from others.

Use of Personal Information

We use personal information for a variety of business purposes, including but not limited to, completing transactions and billing for products and services, responding to your requests for service or assistance, verifying your identity, anticipating and resolving potential and or actual problems with our products and services, creating and improving products and services; suggesting different or additional products or services, making internal business decisions about current and future offers, providing personalized user experiences and service, and protecting our property and rights. We may also use personal information to contact you about GWI or third-party products, services, and offers, consistent with our CPNI Policy set out below, that we believe you may find of interest. We may contact you by telephone, postal mail, e-mail, or other methods. You may opt-out of receiving marketing communications from us at any time by contacting marketing@gwi.net.

Disclosure of Personal Information

We do not rent, sell, or otherwise provide your personal information to unaffiliated third-parties to market their services or products to you. We may, however, disclose your personal information to unaffiliated third-parties as follows: We can disclose personal information about you to third-parties with your consent. We can obtain your consent in several ways, such as in writing, orally, online, through “click-through” agreements, including through interactive voice response, or when your consent is part of this policy or the terms and conditions pursuant to which we provide you service. Your consent is sometimes implicit. For example, if you purchase a product and ask that it be shipped to your home, you implicitly consent to our disclosure of your name and address to a third-party shipping company to complete delivery.

Transaction Processing: We may disclose personal information to third-parties who complete transactions or perform services on our behalf (for example, customer service, billing, shipping, and marketing), and transactions on your behalf (such as, verification of your account information at your request to some third-party business), or transfers related to your service (for example, number portability). We typically restrict by contract the manner in which these third-parties may use and disclose personal information about you without your consent.

Primary Account Holder: We may disclose personal information of an account user to the primary account holder (which is the party financially responsible for the account). If a business, governmental agency, or other individual obtains service for you, that entity or individual is our customer, and we may provide personal information about you or your use of the service to them or others at their direction. When you are the primary account holder, but you receive special terms or discounted pricing, or other benefits through another party’s agreement with us (such as an employee discount), we may provide enough personal information to that party to verify your initial and continuing eligibility for benefits under their agreement with us and to calculate any associated discounts.

Legal Process and Protection of GWI and others: We may disclose personal communications or information where we believe in good faith such disclosure is necessary to comply with the law or respond to legal process (such as a lawful subpoena, E-9-1-1 information, court order), to initiate, bill, render, and collect for products and services, to enforce or apply agreements, to protect our rights and or property in connection with disputes, claims, or litigation; to protect users of our services and other carriers or providers from abusive, fraudulent, or unlawful use of, or subscription to, such services, to facilitate or verify the appropriate calculation of any fees, taxes, or other obligations due to a local, state, or federal government, or if we so determine disclosure is necessary in an emergency situation.

Third-party Services: When the use of our services allows you to take advantage of products and services offered by other companies your personal information may be disclosed.

Business Transfers: We may disclose personal information as part of a corporate business transaction, such as a acquisition or merger, corporate reorganization, or sale of company assets, joint venture, financing, or in the unlikely event of insolvency, receivership or bankruptcy, in which personal information could be transferred to third-parties as a business asset in the transaction.

Retention of Personal Information and Security

We use a variety of electronic, physical, and procedural safeguards to protect personal information from unauthorized use, access, or disclosure while it is under our control. For example when you provide sensitive information (like credit card numbers) to our web site, we use transmission encryption technologies like Secure Socket Layer (SSL). Although we cannot guarantee that misuse, loss, or alteration of your personal information will not occur, we strive to prevent such occurrences.

Our practices and procedures are designed to limit personal information access to those GWI employees and agents with a legitimate need to access such information. GWI employees are bound by confidentiality obligations, which obligate them to protect the confidentiality of our customers’ personal information. Violations of such would subject employees to disciplinary action, up to and including termination.

We retain personal information for as long as we have a business need or as applicable regulations and laws, or government orders require. When we dispose of personal information, we use reasonable procedures to erase or render it unreadable such as shredding documents and wiping electronic media. We will make reasonable attempts to notify you if we determine that a security breach involving your personal information has occurred and creates a risk of service disruption, identity theft, or as otherwise required by law.

Access to Your Information

You may modify your contact information by contacting Customer Service. We will make good faith efforts to resolve requests to correct inaccurate information except where the request requires disproportionate technical effort or expense, is unreasonable, jeopardizes the privacy of others, or would be impractical.

Use of Your Information

Regarding our marketing communications you may choose to limit or opt-out of certain communications from GWI at any time. While you may elect not to receive marketing information from us, if you subscribe to our services, you will continue to receive customer-service and transactional notices, invoices, and similar communications. If you are a GWI customer you can change your marketing preferences by completing our customer opt-out form. If you are not a GWI customer and would like to opt-out of marketing communications from GWI, you can do so by completing our non-customer opt out form. You can also manage your marketing preferences by contacting Customer Service, or, with respect to marketing e-mails, by following the “unsubscribe” instructions on any marketing e-mail we send you.

Children

We do not solicit children to purchase our products or services. If however, you authorize a child to use our products or services through your GWI account, any personal information associated with such use will be treated as your information in accordance with this policy. We encourage parents to be involved in all the online activities (including wireless Internet browsing) of their children to ensure that no information is collected from a child without parental permission. We may offer security features designed to allow the customer to implement restrictions to adult orientated content, but such features are not guaranteed nor are they foolproof.

Caller ID Blocking

When you use GWI’s communications services, your name and telephone number may be transmitted and displayed on the receiving party’s communications device and/or phone bill unless you block that information, which you can generally do by dialing *67 prior to dialing the called party’s phone number. For more details refer to the specific instructions for your communication device regarding Caller ID Blocking. Caller ID Blocking does not prevent the display of your information when you dial certain business numbers, including 911, toll-free numbers or 900 numbers.

Web Beacons, Cookies and Similar Technologies

We may use cookies (which are small data text files placed on your device or computer) or similar technologies to identify the device or computer and record your preferences and other data so that our web site can personalize your visit/s. We may also use information collected from cookies to improve our site, make recommendations, and complete transactions you request. You may be able to set your browser to reject cookies or delete cookies, but that may result in the loss of some functionality on our site. We may also use Web beacons (which are small graphic images on a Web page or an HTML e-mail) to monitor interaction with our web site/s or e-mails. Web beacons are generally invisible because they are very small (only 1-by-1 pixel) and the same color as the background of the Web page or e-mail message. If we combine or link cookie or Web beacon information with personal information, we will treat the combined or linked information as personal information under this policy. We may employ third-parties to place advertisements about our products and services on other web site/s. The use of cookies, Web beacons, or similar technologies by such third-parties is subject to their privacy policies – not this policy.

Customer Service Monitoring

We may record and monitor e-mails, phone calls, or other communications between you and our Customer Service representatives or other employees for quality assurance purposes and training and to review specific transaction requests.

Forums and Chat Rooms

If you use or link to a public bulletin board, forum, chat room, or any type of social network on or from a GWI web site, please understand and be aware that any personal information you submit can be read, collected, or used by other users of these forums, including to send you unsolicited messages. We are not responsible for access to or use of any personal information you choose to submit or share with others.

Directories

We do not publish directories of our customer’s numbers. Neither will we provide or make such numbers available to any third-parties for listing in their public directories, without the customer’s prior consent.

Other Governing Terms

This policy does not alter or modify any applicable agreement you have with GWI. Also, if you subscribe to our services, our GWI Terms and Conditions and certain other terms may apply to your purchase, use, or subscription. If this policy conflicts with any portion of those terms and agreements, those terms and agreements govern to the extent of the inconsistency as permitted by law.

Protecting Your Own Personal Information

You play a key role in ensuring the security of your personal information, including protecting against unauthorized access to your device. We encourage you to use passwords to prevent unauthorized access to your information and your voicemail. We recommend that you periodically change your passwords, use unique, non-obvious passwords, and that you not share your passwords with others. Notify us immediately if you believe your personal information has been accessed without your consent.

Customer Proprietary Network Information (CPNI)

Customer Proprietary Network Information, or “CPNI”, is a form of personal information that is generated in connection with the phone services we provide to you. CPNI includes information such as call details, and certain information about your rate plans and features. CPNI however does not include your name, phone number and address. Under federal law, you have a right, and we have a duty, to protect the confidentiality of CPNI and we have adopted procedures and policies designed to ensure compliance with those rules. We won’t intentionally disclose your CPNI to third-parties without your permission, except as allowed under applicable law, FCC rules, or explained in this policy. However you may designate other “authorized users” (such as a spouse) to access and manage your account information, including CPNI.

USE OF CPNI

We may use CPNI in the course of providing repair services to you. We may also use CPNI to market GWI services to you that may enhance services that you already receive from GWI. Finally, we may use, disclose or permit access to CPNI to protect the rights or property of GWI or to protect users of GWI’s services from fraudulent, abusive or unlawful use of, or subscription to, such services.

USE OF CPNI UPON AUTHORIZATION FROM THE CUSTOMER

We may use CPNI or disclose CPNI to GWI’s agents and any affiliates that provide communications-related services for the purpose of marketing communication related services to you that are outside the category of service to which you already subscribe. As an example, we may utilize CPNI generated in our furnishing phone service to you to market to you, data services. However, you have the right to restrict our use of your CPNI for this purpose. If you would like to opt out of this type of marketing, you may notify us in writing by mailing such writing to: Marketing, GWI 40 Maine Street, Suite 13-127, Biddeford, ME 04005 or you may call customer service and a customer service representative will note your desire to opt out in your billing record. If you do not notify us within 30 days of this notification that you wish to restrict our use of your CPNI, we will conclude that you consent to our use of CPNI for this limited purpose. The approval shall be valid until you affirmatively revoke or limit such approval. Your decision to opt out of such marketing will not affect the provision of any services to which you subscribe. Your decision to permit such marketing may enhance our ability to offer products and services tailored to your needs.

GWI, hereafter referred to as GWI, is responsible for securing its network and computing systems to a reasonable and economically feasible degree against unauthorized access and/or abuse, while making them accessible for authorized and legitimate users. This responsibility includes informing users of expected standards of conduct and the punitive measures for not adhering to them. GWI, in its sole and absolute discretion, may suspend or terminate a user's access to GWI's networks and computing systems following such user's attempt to violate the provisions of this policy, regardless of the success or failure of the attempt.

The users of GWI's networks and computing systems are responsible for respecting and adhering to local, state, federal and international laws. Any attempt to break those laws through the use of GWI's network or computing systems may result in prosecution against the offender by the proper authorities. If such an event should occur, GWI will fully comply with the authorities to provide any and all information necessary for the prosecution process. This compliance may include real time logging of customer activities. GWI reserves the right to modify this policy from time to time as it determines, in its sole and absolute discretion, to be necessary.

General Computing Policy

Once a user receives an account to be used to access GWI's network and computer systems, as well as remote networks and computer systems, they are solely responsible for all actions taken while using that account. The user will, therefore, indemnify, defend, and hold harmless GWI, its shareholders, officers, directors, employees, and agents, for any and all damages or losses, incurred through use of that account. The user will be solely responsible for all indirect, special or punitive damages, resulting from the use of the GWI networks and computing systems. Therefore:

Applying for an account under false pretenses is construed as a violation of the terms of this agreement.

Sharing your account with any other person is prohibited.

In the event that you do share your account with another person, you will be solely responsible for the actions of that other person.
Deletion, examination, copying, or modification of files and/or data belonging to other users without their prior consent is prohibited.

Attempts to evade or change resource quotas are prohibited. Continued impedance of other users through mass consumption of system resources, after receipt of a request to cease such activity, is prohibited. Any unauthorized and deliberate action which damages or disrupts a computing system, alters its normal performance, or causes it to malfunction is a violation regardless of system location or time duration. Any other use of an account which is inconsistent with the terms of service associated with such an account type, such terms of service being defined under GWI's Services Listing.

Electronic Communications Policy

Whenever you send electronic mail, your name and username are included in each mail message. Likewise, use of other services such as news and IRC for electronic communications are attributed to your username. You are responsible, therefore, for all electronic communications originating from your userid. Therefore:

Forgery (or attempted forgery) of electronic mail messages is prohibited.

Attempts to read, delete, copy, or modify the electronic mail of other users is prohibited.

Attempts at sending harassing, obscene and/or other threatening communications to another user via email, posting to a news group or IRC, or transmitting via any other communications service, is prohibited.

Attempts at sending unsolicited junk mail or chain letters is prohibited.

Network Security Policy

As a user of the network, you may be allowed to access other networks (and/or the computer systems attached to those networks). Therefore:

Use of GWI computer systems and / or networks in attempts to gain unauthorized access to remote systems is prohibited.

Use of GWI computer systems and / or networks to connect to other systems in a manner which is intended to interfere with this other system's normal operation, is prohibited.

Decryption of system or user passwords is prohibited.

The copying of system files is prohibited.

The copying of copyrighted materials, such as third-party software, without the express written permission of the owner or the proper license, is prohibited.

Intentional attempts to "crash" Network systems or programs are construed as violations of the terms of this agreement.

Any attempts to secure a higher level of privilege on Network systems are construed as violations of the terms of this agreement.

The willful introduction of computer "viruses" or other disruptive / destructive programs into GWI's computer systems or the use of GWI's networks and computer systems to promulgate viruses onto external networks is prohibited.

Responsibility For Charges Associated With Use Of Services

It is the user's sole responsibility to ensure they completely disconnect from the GWI network. Therefore:

Users are responsible for all connect time associated with their account.

Users are liable for all unintended charges which result from failure to disconnect completely from the GWI network. GWI reserves the right, in its sole and absolute discretion, to issue full or partial credit for such incidents.

Users are liable for all charges incurred, whether intended or unintended, while using our Travel Access Service, billable at $.09 per minute. Charges will not be refunded due to a user's failure to change back from the Travel Access number to a regular local dial-up number.

Interruption Of Service/Liability

The liability of GWI for damages arising out of the provisioning of its Services, including mistakes, interruptions, omission, delays, errors, or other defects, representations, or use of the services or arising out of the failure to furnish the service, whether caused by acts or omission or negligence of the GWI's employees or agents, shall be limited to the amount the GWI would have charged the user for the service period during which the aforementioned faults occurred. The extension of such allowances for interruption shall be the sole remedy of the user and the sole liability of GWI. GWI will not be liable for any direct, indirect, incidental, special, consequential, exemplary, or punitive damages to the user as a result of any GWI service, equipment or facilities, or the acts or omissions or negligence of GWI's employees or agents.

Changes to This Policy

We may update this policy if legal or regulatory changes require it or if we materially change our practices. If we decide to use or disclose personal information in a way that is materially different from that which was stated in this policy at the time the personal information was collected, we will notify you by posting notice of the change on our Web site privacy policy page for at least 30 days before we implement that change and will give you an opportunity to opt-out of the proposed use or disclosure of previously collected personal information. You should refer to this policy often for the latest information and the effective date of any changes.

How to Contact Us

If you have any questions or comments about this policy or about GWI’s privacy practices, please contact Customer Service by sending an e-mail message to services@gwi.net, by accessing Customer Service through our web site or by calling Customer Service at 866-494-2020.

You may also direct your privacy-related comments or questions to the address below:

Marketing
GWI
40 Main Street
Suite 13-127
Biddeford, ME 04005