February 6, 2015 JOHN THUNE, SOUTH DAKOTA, CHAIRMAN ROGER WICKER, MISSISSIPPI ROY BLUNT, MISSOURI MARCO RUBIO, FLORIDA KELLY AYOTTE, NEW HAMPSHIRE TED CRUZ, TEXAS DEB FISCHER, NEBRASKA JERRY MORAN, KANSAS DAN SULLIVAN, ALASKA RON JOHNSON, WISCONSIN DEAN HELLER, NEVADA CORY GARONER, COlORADO STEVE DAINES, MONTANA BILL NELSON, FLORIDA MARIA CANTWELL, WASHINGTON ClAIRE McCASKilL, MISSOURI AMY KlOBUCHAR, MINNESOTA RICHARD BLUMENTHAL, CONNECTICUT BRIAN SCHATZ, HAWAII eDWARD MARKEY, MASSACHUSETTS CORY BOOKER, NEW JERSEY TOM UDALL. NEW MEXICO JOE MANCHIN III, WEST VIRGINIA GARY PETERS. MICHIGAN tlnitrd ~tatfS ~fnatf COMMITTEE ON COMMERCE, SCIENCE, AND TRANSPORTATION WASHINGTON, DC 20510-6125 DAVID SCHWIETERT, STAFF DIRECTOR KIM LIPSKY, DEMOCRATIC STAFF DIRECTOR WEBSITE: http://commerce.senate.gov The Honorable Tom Wheeler Chairman Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Received & InSpected FEB 732015 FCC M ./al Room Dear Chairman Wheeler: We recently wrote to Verizon concerning news reports that a third-party advertising company had been exploiting a mobile tracking technology - colloquially known as a "supercookie" - that Verizon developed to collect information on the wireless Internet activity of its 100 million customers. A copy of that letter and the response we received from Craig Silliman, Verizon's Executive Vice President, Public Policy and General Counsel, are attached. As you know, consumer privacy has long been a priority of the Commerce Committee. As we consider whether legislation may be necessary to fully protect consumers from the use of these supercookies, we also believe the Federal Communications Commission should use its full existing statutory authority to examine these practices. In particular, the use of these supercookies may implicate the Commission's rules and policies related to consumer privacy and transparency. Thank you and we look forward to your response. Sincerely, ~Ut}l/~ Bill Nelson CC: John Thune, Chairman Craig L. Silliman Executive Vice President Public Policy & General Counsel Verizon Communications Inc. 1095 Avenue of the Americas New York, New York 10036 Phone 212-395-2384 Fax 908-766-3834 February 4, 2015 VIA EMAIL AND HAND DELIVERY The Honorable Bill Nelson The Honorable Richard Blumenthal The Honorable Brian Schatz The Honorable Edward J. Markey United States Senate Washington, D.C. 20510 Dear Senators: I am writing in response to your letter of January 29th, 2015 to Lowell C. McAdam, Chairman and CEO of Verizon, in which you inquired about Verizon’s use of an identifier, known as a “Unique Identifier Header” or “UIDH.” Privacy is important to Verizon, and we have implemented our advertising programs in a way that protects our customers’ privacy. We never share information that individually identifies our customers with third parties and we give customers appropriate choices about whether and in what circumstances they will see advertising that is tailored to them. We are also sensitive to concerns raised by our customers, and we make changes to our programs to address their concerns. For example, last week we announced that we are implementing a process to automatically disable the UIDH for customers who opt out of our advertising program. I am answering the specific questions you raise here and would be happy to discuss these issues with you further if that would be helpful. Our advertising programs. Verizon has two advertising programs that use the UIDH. In both the Relevant Mobile Advertising (“RMA”) and Verizon Selects programs, Verizon works with select ad technology partners to identify audiences an advertiser is trying to reach on a Page 2 mobile device and to deliver relevant ads to those customers. The Relevant Mobile Advertising program is similar to direct mail campaigns with which consumers have long experience where, for example, a local pizza restaurant sends ads only to households in a certain geographic area. For this program, Verizon creates groups of customers for advertisers to reach based on the subscribers’ postal address, basic information about their Verizon services, and demographic and interest based information provided to us by other companies. We then relay anonymous information about these groups to our ad partners to enable them to serve relevant ads. If a customer has opted in to Verizon Selects, we will create groups of customers using additional information we have about customers' location, web browsing, and app usage. Customers can choose whether to be a part of these programs at any time through opt- out (Relevant Mobile Advertising) or opt-in (Verizon Selects) choices found on their privacy settings online, on their device in My Verizon, or via our toll free number at (866) 211-0874. Verizon does not disclose our customers' web browsing or personal information to third parties as part of either of these programs, and our ad technology partners are not permitted to use what they receive from Verizon for any purposes outside of the programs. When a customer opts out, our partners receive no information, anonymized or otherwise, about those customers. Verizon also requires our ad partners be part of the Digital Advertising Alliance ("DAA"), which established a privacy code of conduct for the online advertising industry. The UIDH. The UIDH is a temporary, anonymous identifier Verizon includes with unencrypted web traffic transmitted over our wireless network. For example, when a customer types on his or her phone the web address of a retailer, that request travels over the network and is delivered to the retailer site. The information included in that request includes things like the device type and screen size so that the retailer site knows how to best display the site on the phone. The UIDH is included in this information. The UIDH was designed with privacy protections in place – it changes automatically and frequently to protect the privacy of our customers. The UIDH is not used to collect any customer information, including web browsing information. In addition, the UIDH does not contain any customer information. In addition, the UIDH is present on only some traffic. Specifically, it is present on unencrypted web traffic over our wireless network. The UIDH is not present on encrypted traffic (https) or when a device is connected through Wi-Fi or Virtual Private Networks. Identifiers like the UIDH are commonly used in the mobile Internet ecosystem to identify devices and enable targeted mobile advertising. Both of the major mobile operating systems employ advertising identifiers for use by third party advertisers in applications. Users of these devices can opt out of ad targeting, but they cannot disable the identifiers from being transmitted. And these identifiers can be manually changed by users, but they do not rotate automatically like the UIDH. Unless a user manually changes a device’s settings, the identifiers remain the same. These identifiers are also accessible by apps regardless of whether the end user is using Wi-Fi, Virtual Private Networks, or HTTPs. Since the great majority of mobile usage Page 3 is through apps, much of such use is over WiFi (where the UIDH is not present), and these identifiers are in use on devices for all of the major carriers, these other identifiers are significantly more prevalent than the UIDH. The UIDH enables a number of features for Verizon’s customers while protecting their privacy. It enables advertisers to send more relevant ads to those Verizon users who want the ads they see to be better targeted at their interests, without the advertisers ever knowing to whom the ads are being sent. The UIDH has other uses as well. For example, the UIDH can be used to authenticate the device as valid on the Verizon network. In addition, instead of requiring a customer to manually fill in his or her own information on a website, the UIDH could be used as an anonymous identifier by which the website could request, with customer consent, Verizon to provide information it has about the customer. Recent news reports have raised concerns about how TURN, a third-party online advertising company, has used the UIDH for purposes outside of Verizon's advertising programs. TURN has announced its intent to discontinue this practice and we are working with our other partners to ensure that their use of UIDHs is consistent with the purposes we intended. Below are answers to your specific questions. 1) When did Verizon learn that Turn was using Verizon’s persistent, network-based mobile tracker to regenerate deleted cookies? Verizon learned that Turn was using the UIDH to regenerate deleted cookies in January, 2015 when ProPublica contacted Verizon and asked for comment on a story it was writing. 2) Are Verizon officials aware of other online third parties that are using this persistent mobile tracker for similar purposes? No. 3) What, if any, information and disclosures does Verizon provide its wireless customers about how third-party companies use or can use Verizon’s mobile tracker? How has the policy changed, if at all, given press accounts about Turn? Verizon has proactively provided our customers with clear and easy to understand notices of our advertising programs in a number of different ways. Verizon’s privacy policy explains the types of data that Verizon collects, how the data is used, and whether and in what form that data may be shared. A link to the Privacy Policy can be found in a footer on most of Verizon’s website pages. The Privacy Policy is attached as Exhibit 1. Page 4 In September 2011, existing Verizon Wireless customers began receiving a privacy notice that describes the Relevant Mobile Advertising program. A copy of that notice is attached as Exhibit 2. Customers received notifications regarding this program through direct mail, email and bill inserts. New customers and customers who add a line of service are similarly notified about the Relevant Mobile Advertising Program. Customers must affirmatively opt-in to the Verizon Selects program. Verizon notifies its customers of the terms and conditions for Verizon Selects prior to the time that the customers opt-in. The Verizon Selects terms and conditions are attached as Exhibit 3. Customers may also see information about Verizon’s advertising programs when navigating the Verizon Wireless website while they are completing purchases, making changes to, or upgrading their accounts, or when accessing their account profiles through the My Verizon webpage or My Verizon Mobile App. After news articles appeared about the UIDH late last year, we posted answers to frequently answered questions about the UIDH. We modified those answers after the press accounts appeared about Turn to explain that Turn had announced it would discontinue certain practices. In addition, our advertising partners have confirmed that they do not use the UIDH to regenerate deleted browser cookies. Our answers to the frequently asked questions can be found at http://www.verizonwireless.com/support/unique-identifier-header-faqs/. 4) Does Verizon intend to continue the use of its mobile tracker? If so, what steps will the company take to protect consumer choice and prohibit similar violations of their privacy, both from Verizon itself and from third-party companies? Verizon intends to continue to use the UIDH. As we explain above, Verizon’s programs have been designed to protect our customers’ privacy and to provide our customers with choices about whether to participate. We do not share information that individually identifies our customers with third parties. In addition, Verizon is working to automatically disable the UIDH for customers who are opted out of the RMA program or who opt out in the future. Verizon will also disable the UIDH for any customers who are ineligible to participate in these advertising programs, such as government and enterprise lines. We are in the process of making the systems changes needed to deliver these solutions, and will begin implementing modifications in locations across the country once testing is complete. Further, we have confirmed with all of our advertising partners that they will not use the UIDH to regenerate deleted browser cookies. Sincerely, Verizon Participates in the TRUSTe Privacy Program [ more ] Verizon is accredited by the Better Business Bureau Online (BBBOnLine) [ more ] Privacy Policy Summary Full Privacy Policy Privacy Officer Message Recent Changes to the Policy Tips for Guarding Your Information FiOS Privacy Policy Your California Privacy Rights Your Ohio Rights & Responsibilities EU Safe Harbor About / Privacy Policy / Full Privacy Policy Feb 4, 2015 9:07 AM | VZ 47.83 +0.85 | Disclaimer Privacy Policy Full Privacy Policy Verizon is Committed to Protecting Your Privacy Protecting our customers' privacy is an important priority at Verizon and we are committed to maintaining strong and meaningful privacy protections. The privacy of your information is a significant responsibility and we value the trust you place in us. Our Privacy Policy is designed to inform you about the information we collect, how we use it, and your options with regard to that collection and use. This policy also describes privacy rights you have under certain federal laws. This policy applies to Verizon customers in the United States and to visitors to Verizon websites. For Verizon Business customers outside the United States, policies are set forth at http://www.verizonenterprise.com/terms/. Also, certain services offered to consumers as well as contracts between Verizon and its business customers (both U.S. and international) may contain additional privacy-related terms and conditions. Except as described above, this policy applies across the Verizon family of companies and the products and services they provide. The Verizon family of companies includes the companies and joint ventures controlled by Verizon, including the Verizon telephone companies, Verizon Wireless, Verizon Online and Redbox Instant by Verizon. This policy also includes additional privacy practices that are applicable to specific Verizon offerings such as FiOS, Wireless and Redbox Instant by Verizon services. Back to Summary Information We Collect and How We Use It We collect and use information about you in the following ways: Information Collected When You Communicate with Verizon: When you communicate with Verizon, we collect information from you that we use to deliver, provide, confirm, change, bill, monitor, maintain and repair your products and services. This information is also used to resolve issues with your order, with our products and services, or with your account. The information we collect may include your name, addresses, and other contact information; images you provide; the reason for the contact; and your driver’s license number and Social Security Number and payment information. We use this information to establish and maintain your customer account and billing records (including establishing credit), provide services to you, authenticate you, and contact you about products and services that we offer. When you contact us or we contact you with calls, e-mail, in writing, or through a feature on our websites or in our applications, we may monitor or record that communication or keep a record of the transaction to help us train employees and provide high-quality customer service. Information Collected When You Use Verizon Products and Services: We collect information about your use of our products, services and sites. Information such as call records, websites visited, wireless location, application and feature usage, network traffic data, product and device-specific information and identifiers, service options you choose, mobile and device numbers, video streaming and video packages and usage, movie rental and purchase data, FiOS TV viewership, and other similar information may be used for billing purposes, to deliver and maintain products and services, or to help you with service-related issues or questions. In addition, this information may be used for purposes such as providing you with information about product or service enhancements, determining your eligibility for new products and services, and marketing to you. This information may also be used to manage and protect our networks, services and users from fraudulent, abusive, or unlawful uses; and help us improve our services, research and develop new products, and offer promotions and other services. If you subscribe to Verizon Internet access services, we may automatically measure and monitor network performance and the performance of your Internet connection to improve your, or our, service levels and products. If you contact us for service support, we also may access information about your computer, wireless device or other device settings to provide customized technical Español Contact Us My VerizonRESIDENTIAL BUSINESS WIRELESS ([KLELW support or to install specific applications or services that you use or that are necessary to the applications or services you use. This type of information may be aggregated or anonymized for business and marketing uses by us or by third parties. For example, aggregate or anonymous data may be used to improve our services, measure and analyze the use of services and to help make services and advertising more relevant to customers. When you establish an online account with us, we maintain information about your user identification, password and secret questions and answers. This information is used to identify you when you sign in to your account. If Verizon intends to gather information from your use of our Internet access services to direct customized advertising specifically to you based on your visits over time and across different non-Verizon websites, we will provide you with notice of our plan and obtain your affirmative consent. Please note that Verizon is not responsible for information, content, applications or services provided by others. Before you access, use, link to or download a service or application on your computer, television, wireless or other device, you should review the associated terms of service and privacy policy. Personal information you submit in those contexts may be read, collected or used by the service or application provider and others associated with these forums in a manner different from that described here. Information Provided to Us by Third Parties: When you purchase products or apply for service with us, we may obtain credit information about you from outside credit reporting agencies to help us with customer authentication and credit-related decisions. If you lease your residence, we may have information about how to reach your landlord and whether landlord permission is required to install our facilities. Verizon obtains information from outside companies that collect consumer information such as demographic and interest data. Examples of this information include gender, age range, sports enthusiast, frequent diner or pet owner. We use this data and combine it with other information we have about you to help us predict customer preferences and to direct marketing offers that might be more relevant to you. When you use social media credentials to login to or otherwise interact with a Verizon site or offer, we may collect information about your social media profile, such as your interests, “likes” and friends list. We may use this information, for example, to personalize your Verizon experiences and marketing communications, to enhance our services and to better serve you. You can control this data sharing via options in your social media accounts. We may also obtain contact information and other marketing lead information from third parties, and may combine it with information we have to contact you or direct Verizon's marketing offers to you. Website visitors and others may provide us with your email address through "refer-a-friend" options or social networking platforms. We use these email addresses to send Verizon promotional marketing information. Information Collected on Verizon Websites: When you browse Verizon websites, information is collected about your device and your visit. We also collect data about your browsing, searching and buying activity as you interact with our sites. We may collect and use your IP address, mobile telephone or device number, account information, web addresses of the sites you come from and go to next and information about your connection, including your device's browser, operating system, platform type and Internet connection speed. We use this information for operational, performance measurement and other business purposes. Verizon and its vendors also use this information to help us deliver more relevant Verizon marketing messages. These messages may be delivered on our websites, on non-Verizon websites, by our representatives, via email, or via other Verizon services or devices. We use this information in order to, among other things, ensure that you see the correct products and pricing available in the geographic area in which you live, manage the frequency with which you see an advertisement, tailor advertisements to better match your interests, and to understand the effectiveness of our advertising. We also may use this information to assess the effectiveness of our sites and to help you should you request help with navigation problems on these sites. Certain Verizon vendors may place and read cookies on our sites to help us deliver Verizon marketing messages on our sites and on non-Verizon sites. We require that these vendors provide consumers with the ability to opt-out of their use of information for these purposes. In accordance with industry self-regulatory principles, you should see this icon in or around Verizon advertisements that are delivered on other sites using information collected on our sites. Clicking on this icon will provide information about the companies and data practices that were used to deliver the ad and will also describe how you may opt-out of these advertising programs. Additional information on the choices available to you for the use of your information for advertising purposes can be found in the "How to Limit the Sharing and Use of Your Information" section below. Additional information about "cookies" and related technologies When you register on our sites, we may assign an anonymous, unique identifier. This may allow select advertising entities to use information they have about your web browsing on a desktop computer to deliver marketing messages to mobile devices on our network. We do not share any information that identifies you personally outside of Verizon as part of this program. You have a choice about whether to participate, and you can you can visit our relevant mobile advertising page (link to www.vzw.com/myprivacy) to learn more or advise us of your choice. Back to Summary Information You Provide: When you contact us online or by other means for information about products and services or when you enter a Verizon-sponsored or affiliated contest, sweepstakes or similar promotion, we will respond to your request and may use the information you supply to provide you with additional information about other Verizon services, programs or offerings either at that time or in the future. If you enter a promotion, your information may be disclosed as part of the program’s administration, such as in connection with the publication of winners, prize fulfillment, and as required by law or permitted by the promotion’s official rules. Information you provide on our websites about your preferred location and other preferences may be used to provide you with more relevant product recommendations, services and special offers. If you provide information to us in the context of an event that Verizon sponsors with another organization, such as a contest or sweepstakes, or if you visit a co-sponsored site or use a co-sponsored service, you also may be providing information to the co- sponsor. You should refer to that co-sponsor's privacy policy for information about its practices which may differ from Verizon's practices. We may also collect information from you when you agree to participate in surveys or provide other feedback to us regarding our products or services, when you register to receive news or public policy updates, or when you apply for a job with or a grant from Verizon. We use this information only for the purpose for which you provide it. Verizon may send you emails that communicate information about your account or about products, services, marketing offers, or promotions that may be of interest to you. When you open a Verizon email or click on links within these emails, we may collect and retain information to provide you with future communications that may be more interesting to you. Please note that Verizon will not ask you to send us, via email, sensitive personal or account information. Back to Summary Additional Information for Wireless Customers Verizon Wireless collects and uses mobile device location data for a variety of purposes, including to provide our mobile voice and data services, emergency services, and our and third-party location-based applications and services such as navigation, weather, mapping and child safety applications or tools. Where we offer our own location-based applications, we provide you with notice and choice about whether specific location-tracking features available on your device are turned on. Many types of wireless applications and services use mobile device location data, including applications provided by other companies and wireless device operating systems. When you are considering new applications or services, you should carefully review the location-based services' or application providers' privacy policies to learn how they collect and use your information. Verizon Wireless may use mobile usage information and consumer information for certain business and marketing reports. Mobile usage information includes the addresses of websites you visit when you use our wireless services. These data strings (or URLs) may include search terms you have used. Mobile usage information also includes the location of your device and your use of applications and features. Consumer information includes information about your use of Verizon products and services (such as data and calling features, device type, and amount of use) as well as demographic and interest categories provided to us by other companies (such as gender, age range, sports fan, frequent diner, or pet owner). We may combine this information in a manner that does not personally identify you and use it to prepare aggregated business and marketing reports that we may use ourselves or share with others for their use. We may also share location information with other companies in a way that does not personally identify you so that they may produce business and marketing reports. You have a choice about whether your information is included in these reports. Verizon Wireless does not publish directories of our customers' wireless phone numbers, and we do not provide or make them available to third parties for listing in directories unless you request that we do so. Back to Summary Information About the Cable Act To the extent that Section 631 of the Communications Act of 1934, as amended (the "Cable Act") applies to services you purchase, it entitles you to know about the personally identifiable information a cable service provider collects. This includes the nature of the use and disclosure of this information and to whom it may be disclosed, how long personally identifiable information is maintained, and how subscribers may access it. In addition, the Cable Act imposes limits on the collection and disclosure of personal information and gives subscribers the ability to enforce their privacy rights. (Personally identifiable information does not include aggregate data that does not identify a particular person). The Cable Act allows a provider to use its cable system to collect personally identifiable information necessary to render a cable service or other services provided to subscribers and to detect and prevent unauthorized access to services. Additional personally identifiable information may be collected with the subscriber’s prior consent. Personally identifiable information may be used or disclosed without the subscriber’s consent where necessary to render services, and to conduct legitimate business activities related to services provided. We may be required by law to disclose personally identifiable information to a governmental entity to comply with valid legal process, such as warrants, court orders or subpoenas, but we will not disclose records revealing your selection of video programming unless we receive a court order indicating that the governmental entity has made a specified showing of relevance and you were afforded an opportunity to contest the order. We may be required to disclose personally identifiable information (including your selection of video programming) to a non-governmental entity to comply with a court order, after you have been provided notice. If you believe that your privacy rights have been violated, please contact us at privacyoffice@verizon.com and we will work with you to address your concerns. If you believe that you have been aggrieved as a result of a violation of the Cable Act, you may enforce the limitations imposed by the Cable Act through a civil action in a United States district court seeking damages, attorney's fees, and litigation costs. Other rights and remedies may also be available to you under federal or other applicable laws. The Cable Act permits the disclosure of customer names and addresses as long as a subscriber has been provided with the opportunity to prohibit or limit this disclosure and the disclosure does not reveal, directly or indirectly, the subscriber’s viewing or other uses of the cable or other services provided. If we intend to share data in this way, we will provide you with the opportunity to prohibit or limit this type of sharing. Relevant TV Advertising Verizon’s Relevant TV Advertising program helps advertisers reach FiOS television customers with advertisements that may be more relevant to their interests. We do not share any information that identifies you personally outside of Verizon as part of this program. The ads may appear on a variety of platforms where FiOS television customers can access video content. We help advertisers deliver ads to audiences based on demographic and interest information (such as gender, family size, and luxury car owner) we obtain from other companies, your address and certain information about your Verizon products and services (such as service packages purchased, video on-demand purchases, and program viewing data). You have a choice about receiving this type of advertising and you can opt out online. Additional Information for Redbox Instant by Verizon Customers Redbox Instant by Verizon video streaming services are offered through a joint venture between Verizon and Redbox. When you subscribe to or use Redbox Instant by Verizon services, your information is shared with both Verizon and Redbox and is covered by this privacy policy as well as Redbox’s privacy policy. Redbox Instant by Verizon services will be available to you through websites and Internet-connected device platforms operated by other companies such as gaming devices, streaming video devices, tablets and wireless phones. When you access Redbox Instant by Verizon on others’ websites or platforms, you should check these providers’ privacy policies to learn what information they collect and use. Back to Summary. Information We Share Information Shared Within the Verizon Family of Companies: Verizon shares customer information within our family of companies for a variety of purposes, including, for example, providing you with the latest information about our products and services and offering you our latest promotions. You can limit the sharing of certain types of customer information, known as Customer Proprietary Network Information, or CPNI, within the Verizon family of companies for marketing services to you other than your current services. Customer Proprietary Network Information (CPNI) is information that relates to the type, quantity, destination, technical configuration, location, amout of use, and related billing information of your telecommunications or interconnected Voice over Internet Protocol (VoIP) services. Federal law governs our use and sharing of CPNI. Information Shared Outside the Verizon Family of Companies: Except as explained in this Privacy Policy, in privacy policies for specific services, or in agreements with our customers, Verizon does not sell, license or share information that individually identifies our customers, people using our networks, or website visitors with others outside the Verizon family of companies for non-Verizon purposes without the consent of the person whose information will be shared. Verizon uses vendors and partners for a variety of business purposes such as to help us offer, provide, repair and bill for services we provide. We share information with those vendors and partners when it is necessary for them to perform work on our behalf. For example, we may provide your credit card information and billing address to our payment processing company solely for the purpose of processing payment for a transaction you have requested. We require that these vendors and partners protect the customer information we provide to them and limit their use of Verizon customer data to the purposes for which it was provided. We do not permit these types of vendors and partners to use this information for their own marketing purposes. As described in more detail in other sections of this policy, Verizon also may share certain information with outside companies-, for example, to assist with the delivery of advertising campaigns, or preparing and sharing aggregate reports. Verizon provides the names, addresses and telephone numbers of wireline telephone customers to directory publishers and directory assistance services unless a non-published or non-listed phone number has been requested. We may disclose information that individually identifies our customers or identifies customer devices in certain circumstances, such as: to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law; in cases involving danger of death or serious physical injury to any person or other emergencies; to protect our rights or property, or the safety of our customers or employees; to protect against fraudulent, malicious, abusive, unauthorized or unlawful use of or subscription to our products and services and to protect our network, services, devices and users from such use; to advance or defend against complaints or legal claims in court, administrative proceedings and elsewhere; to credit bureaus or collection agencies for reporting purposes or to obtain payment for Verizon-billed products and services; to a third-party that you have authorized to verify your account information; to outside auditors and regulators; or with your consent. When you purchase services offered jointly by Verizon and one of our partners, customer information may be received by both Verizon and our partner that is providing your service. For these jointly offered services, you should also review the partner company's privacy policy which may include practices that are different from the practices described here. If Verizon enters into a merger, acquisition or sale of all or a portion of its assets or business, customer information will also be transferred as part of or in connection with the transaction. Information Provided to or Used by Third-Party Advertising Entities or Social Networks You may see third-party advertisements on some Verizon websites, services, or devices. Some advertisements are chosen by companies that place advertisements on behalf of other third-party advertisers. These companies, often called ad servers, ad networks, or technology platforms, may place and access cookies on your device to collect information about your visit on our websites. The information they collect from our sites is in a form that does not identify you personally. This information may be combined with similar data obtained from other websites to help advertisers better reach audiences they wish to target. Targeting may be accomplished by tailoring advertising to interests that they infer from your interactions on our sites and your interaction with other websites where these ad servers, ad networks and technology platforms also are present. If you choose to interact with specific advertisers who advertise on our sites or services, the information you provide to them is subject to the conditions of their specific privacy policies. In addition, responding to or interacting with a particular advertisement, may result in you later receiving a targeted advertisement on our websites or on other sites as a result of an ad server or ad network concluding that you fit within a particular audience an advertiser is trying to reach. Advertising that is customized based on predictions generated from your visits over time and across different websites is sometimes called "online behavioral" or "interest-based" advertising. In accordance with industry self-regulatory principles, we require that companies disclose when they are using online behavioral advertising programs to deliver third-party ads on our sites or collecting information about your visit to our sites for these purposes and give consumers the ability to opt-out of this use of their information. You will see an icon in or around third-party advertisements that are delivered on our sites using behavioral advertising programs. Clicking on this icon will provide additional information about the companies and data practices that were used to deliver the ad as well as information on how you may opt-out of these advertising programs. Additional information about your options regarding the use of your information for advertising purposes can be found below. Additional information about online behavioral advertising can be found here. Please note that Verizon does not have control over or access to information contained in the cookies that are set on your computer by ad servers, ad networks or third-party advertisers. Additional information about "cookies" and related technologies We also may permit advertisers on our sites to place ads based on certain information we have about you Verizon products and services as well as geographic and demographic data. Information used for this purpose does not identify you individually. Verizon also helps advertisers better reach our Internet access customers using the postal address we have for you; certain information about your Verizon products and services-- such as device type and broadband service features; and demographic and interest information provided to us by other companies-- such as gender, age-range, sports fan, frequent diner or pet owner. This information is used to predict whether you fit within an audience an advertiser is trying to reach. In addition, using an anonymous, unique identifier we create when you register on our websites, we may allow an advertiser to use information they have about your visits to websites on a desktop computer to deliver marketing messages to mobile devices on our network. We do not share outside of Verizon any information that identifies you personally as part of these programs. You have a choice about participating in the separate Verizon and Verizon Wireless programs. Verizon websites and services may include social network or other third-party plug-ins and widgets that may provide information to their associated social networks or third-parties about your interactions with Verizon page you visit or services you use, even if you do not click on or otherwise interact with the plug-in or widget. More information is available here. Back to Summary How to Limit the Sharing and Use of Your Information You have choices about how Verizon shares and uses information. Customer Proprietary Network Information (CPNI): Customers of Verizon telecommunications and VoIP services may choose to limit the use and sharing of CPNI for Verizon's marketing services outside of services you currently have. Notice about our use and sharing of CPNI and the choices you have may be provided on your monthly bill, over the phone, via text, in contracts or in other ways. Verizon Wireline consumers and certain business customers may opt-out by calling 1-866-483-9700. Verizon Wireless consumer and certain business customers may call 1-800-333-9956. Other customers may decline to provide or withdraw CPNI consent by following the instructions in the Verizon notice seeking consent. For additional information, you can read examples of common consumer CPNI notices for Verizon Wireline and Verizon Wireless. Telemarketing: Federal "Do Not Call" laws allow you to place your phone numbers on the National Do Not Call Registry to prevent telemarketing calls to those numbers. If you would like to add your numbers to this list, you may do so by calling 1-888-382-1222, or by visiting www.donotcall.gov. You should be aware that even if you add your number(s) to the federal or a state Do Not Call list, most telemarketing laws allow companies to contact their own customers. If at any time you would like to be removed from Verizon's residential telemarketing list, please let us know by contacting a Verizon customer service representative at 1-800-VERIZON. Verizon Wireless also maintains a Do Not Call list. If you would like to be removed from the Verizon Wireless telemarketing list, please let us know by contacting a Verizon Wireless customer service representative at 1-800-922-0204. Please allow 30 days for your telephone number to be removed from any sales programs that are currently underway. Marketing Email, Text Messages, Postal Mail and Door-to-Door Calls: Marketing emails you receive from Verizon, Verizon Wireless, or Redbox Instant by Verizon include an unsubscribe instruction (usually found at the bottom of the email) that you may use to opt out of receiving future marketing-related emails. You may opt out of receiving marketing-related emails from Verizon by visiting our "Unsubscribe" site and providing the requested information. You may opt out of receiving marketing-related emails from Verizon Wireless by contacting a Verizon Wireless customer service representative at 1-800-922-0204. You may opt-out of receiving marketing-related emails from Redbox Instant by Verizon at your customer account pages online. You may opt out of receiving marketing-related postal mailings or prevent door-to-door marketing solicitations from Verizon by calling a customer service representative at 1-800-VERIZON. You may opt out of receiving marketing-related postal mailing or prevent text message marketing by Verizon Wireless by calling a Verizon Wireless customer service representative at 1-800-922- 0204. Text message solicitations from Verizon also contain an "unsubscribe" feature that you can use to prevent future marketing text messages from us. Please note that Verizon may use bulk mail service for some marketing mailings. These services deliver offers to all homes in a neighborhood or zip code. This type of mailing will continue even if you opt-out of receiving marketing- related postal mailings from Verizon. Information Used for Online Advertising: You have choices about whether certain information collected on websites, including Verizon's, is used to customize advertising based on predictions generated from your visits over time and across different websites. When you see this icon in or around an advertisement you can click on the icon to see additional information on the companies and data practices that were used to deliver the ad and descriptions of how you may opt-out of these advertising programs. To learn more or to limit the collection of information by these parties, you may also visit the Aboutads.info website. Please note that many opt-outs are cookie-based. If you buy a new computer, change web browsers or delete the cookies on your computer, you will need to opt-out again. Please also note that some wireless devices, portals and websites have limited ability to use and store cookies. As a result, advertising entities may have a limited ability to use cookies in the manner described above or to respect cookie-based opt out preferences. However, ads may still be tailored using other techniques such as publisher, device or browser-enabled targeting. You should check the privacy policies of the products, sites and services you use to learn more about any such techniques and your options. If you do not want information to be collected for marketing purposes from services such as the Verizon Wireless Mobile Internet services, you should not use those particular services. You also can limit the collection of certain website information by deleting or disabling cookies. Most computers' Internet browsers enable you to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. See information about managing cookies Please note that disabling cookies may prevent you from using specific features on our sites and other websites, such as ordering products or services and maintaining an online account. Cookies must be enabled for you to use your Verizon e-mail account. Relevant Advertising Verizon broadband Internet access customers may opt-out of the relevant online advertising program described above by following the instructions here. Verizon Wireless Internet customers may opt-out of the relevant mobile advertising program by following the instructions here or by calling us at 1-866-211-0874. You may opt-out of Verizon’s Relevant TV advertising program by following the instructions here. If you opt out online, you will need your account user ID and password. Also, please note that you will receive ads whether you participate in these programs or not, but under these programs, ads may be more relevant to you. Business and Marketing Reports Verizon Wireless customers may choose not to participate in Verizon Wireless' use of their information to create aggregated business and marketing reports that do not specifically identify any individual Verizon Wireless customers. You may opt-out by calling 1-866-211-0874 or by visiting verizonwireless.com/myprivacy. Please note that if you have a Family SharePlan® or multi- line account, you must indicate your opt-out choice for each line. If you add a line or change a telephone number, you will need to update your privacy choices. Back to Summary Working Together to Keep Children Safe Verizon recognizes that online service providers must be vigilant in protecting the safety and privacy of children online. We do not knowingly market to or solicit information from children under the age of 13, without obtaining verifiable parental consent. Verizon strongly supports educating parents and young Internet users on safe viewing practices and we offer a variety of tools to help children and parents avoid encountering objectionable content or communications while using our services. Verizon's Parental Control Center provides many free resources that offer guidance, connect parents with experts and help give parents the technical knowledge to help keep kids safer online. Regrettably, there are those who use the Internet to view, store and distribute child pornography (or who engage in other types of illegal activity involving children). Child pornography is subject to severe criminal penalties and using the Verizon network to view, store or distribute it violates our service contracts. The Verizon network may not be used by customers in any manner for the storage, transmission or dissemination of images containing child pornography and we will report any instances of such activity of which we become aware to the appropriate law enforcement authorities. If you have a complaint about child pornography, the soliciting of children for sexual activity, or any other illegal or inappropriate activity involving children on a Verizon service, report it to us by sending an email to abuse@verizon.net. Please include the words "child porn" in the subject line of your email. You can also make a report directly to the National Center for Missing and Exploited Children through its CyberTipline located at www.cybertipline.org. Additional Internet safety resources and information are available at: http://www.netsmartz.org/ http://www.wiredsafety.org/ http://www.onguardonline.gov/ http://www.commonsensemedia.org/ http://www.stopbullying.gov/ http://www.cyberbullying.us/ http://www.connectsafely.org/ Back to Summary Information Security and Data Retention Verizon has technical, administrative and physical safeguards in place to help protect against unauthorized access to, use or disclosure of customer information we collect or store, including Social Security Numbers. Employees are trained on the importance of protecting privacy and on the proper access to, use and disclosure of customer information. Under our practices and policies, access to sensitive personally identifiable information is authorized only for those who have a business need for such access. Personally identifiable and other sensitive records are retained only as long as reasonably necessary for business accounting, tax or legal purposes. Although we work hard to protect personal information that we collect and store, no program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose personal information. Verizon maintains security and incident response plans to handle incidents involving unauthorized access to private information we collect or store. If you become aware of a security issue, please contact Verizon's Security Control Center. We will work with you to address any problems. Verizon often publishes helpful information about a wide range of scams that you may encounter. View current information about Internet and phone scams and tips on how to protect yourself Back to Summary Contact Information If you have questions, concerns or suggestions related to our Privacy Policy or our privacy practices you may contact us at: Verizon Privacy Office 1300 I Street, NW Suite 400 West Washington, DC 20005 Fax: 202-789-1432 Email: privacyoffice@verizon.com Accessing and Updating Your Information We strive to keep our customer records as accurate as possible. You may correct or update your Verizon customer information by calling a Verizon customer service representative at 1-800-VERIZON or by accessing your account online and providing the updated information there. Similarly, updates can be made to your Verizon Wireless account by calling a Verizon Wireless customer service representative at 1-800-922-0204 or online. Verizon Business customers may update their information by contacting their account manager. Updates can be made to your Redbox Instant by Verizon account information by visiting the "My Account" pages online. Home Our Company Innovative Solutions Corporate Responsibility News Center Investors Careers Privacy Policy Terms & Conditions © 2013 Verizon If you are a FiOS or other customer served over our fiber-to-the-premises network and you would like to see your personally identifiable information, please contact us at privacyoffice@verizon.com so we may arrange a time and convenient location for you to do so during business hours. You will need to provide proper identification and you may examine records that contain personally identifiable information about you and no one else. If you believe any of your personally identifiable information is inaccurate, we will work with you to ensure that corrections are made. Verizon reserves the right to charge you for the cost of photocopying any documents you request. Links to and from Non-Verizon Websites and Content Verizon websites and Redbox Instant by Verizon platforms may contain links to non-Verizon sites. Verizon applications or other content may be included on web pages and web sites that are not associated with Verizon and over which we have no control. We are not responsible for the content on these sites or platforms or the privacy policies and practices employed by these sites and platforms. We recommend that you review the policies and practices of the sites you visit. Information Sharing: Blogs and Social Networking Some Verizon websites, applications, and services may allow you to participate in web log ("blog") discussions, message boards, chat rooms, and other forms of social networking and to post reviews. Please be aware that these forums are accessible to others. We urge you to not submit any personally identifiable information to these forums because any information you post can be read, collected, shared, or otherwise used by anyone who accesses the forum. Verizon is not responsible for the information you choose to submit in these forums. If you post content to information sharing forums, including any information about the movies you rent or view, you are doing so by choice and you are providing consent to the disclosure of this information. Changes to This Policy We reserve the right to make changes to this Privacy Policy, so please check back periodically for changes. You will be able to see that changes have been made by checking to see the effective date posted at the end of the policy. If Verizon elects to use or disclose information that identifies you as an individual in a manner that is materially different from that stated in our policy at the time we collected that information from you, we will give you a choice regarding such use or disclosure by appropriate means, which may include use of an opt-out mechanism. Updated August, 2014 © 2009, 2011-2014 Verizon. All Rights Reserved. IMPORTANT UPDATE ABOUT HOW VERIZON WIRELESS USES INFORMATION Why am I getting this notice? Your privacy is an important priority at Verizon Wireless. Our Privacy Policy (available at www.verizon.com/privacy) informs you about information we collect and how we use it. Today we want to tell you about some important updates relating to two new uses of information. Verizon Wireless will begin using the information described below for (1) certain business and marketing reports and (2) making mobile ads you see more relevant. If you do not want us to use this information for these purposes, you can let us know by using one of the options described in the "Your Choices" section of this notice. This supplements our Privacy Policy. What information are we talking about? Under these programs, we will not share any information that identifies you personally. Verizon Wireless will use the following categories of information: Mobile Usage Information  Addresses of websites you visit when using our wireless service. These data strings (or URLs) may include search terms you have used.  Location of your device (“Location Information”)  App and device feature usage Consumer Information  Information about your use of Verizon products and services (such as data and calling features, device type, and amount of use)  Demographic and interest categories provided to us by other companies, such as gender, age range, sports fan, frequent diner, or pet owner (“Demographics”) Is my information shared? Under these new programs, we will not share outside of Verizon any information that identifies you personally. How information will be used Description Example To create business and marketing reports. We will combine Mobile Usage Information and Consumer Information in a way that does not personally identify you. We will use this information to prepare business and marketing reports that we may use ourselves or share with others. A report might state that 10,000 mobile users visited a sports website in a month and 60% were men. For other companies to create business and marketing reports. We may also share Location Information with other companies in a way that does not personally identify you. We will allow these companies to produce limited business and marketing reports. The data we provide could be combined with data provided by other wireless carriers to create a report on the number of mobile users who take a particular highway during rush hour. To make mobile ads you see more relevant. When you use your wireless device, you often see ads on websites and apps. Using certain Consumer Information (such as your Demographics, device type, and language preference) and the postal address we have for you, we will determine whether you fit within an audience an advertiser is trying to reach. This means ads you see may be more relevant to you. We will not share any information that identifies you personally. A local restaurant may want to advertise only to people who live within 10 miles, and we might help deliver that ad on a website without sharing information that identifies you personally. Your choices. If you do not want us to use your information for any of the purposes described above, please let us know at any time by:  Visiting www.vzw.com/myprivacy Or  Calling 1-866-211-0874 You will receive mobile ads whether you participate or not, but under the advertising program, ads may be more relevant to you. If you have a Family SharePlan® or multi-line account, you must indicate your choice for each line. If you add a line or change a telephone number, you will need to update your privacy choices. ([KLELW Verizon Selects Participation Agreement [Important Consumer Information] What is Verizon Selects? As a participant in Verizon Selects, you may receive marketing messages, offers, and other content that interest you more than what you receive today. Verizon Selects uses information about you to see whether you fit into an audience Verizon or another company is trying to reach. We will not share information that identifies you personally with any non- Verizon companies. Verizon Selects will use your information to provide relevant marketing messages through a variety of marketing media such as postal mail, email, text, Internet, and mobile advertising. What information are we talking about? Mobile usage information Addresses of websites you visit when using our wireless service. These data strings (or URLs) may include search terms you have used. Location of your device. Apps and device feature usage. Other types of information Demographic, interest and behavior characteristics provided to us by other companies, such as gender, age range, sports fan, pet owner, shopping preferences, and ad responses. Demographic, interest and behavior characteristics developed by Verizon. Information about the quantity, type, destination, location, and amount of Verizon Selects Verizon Selects is a program you can choose to participate in that uses information about you, including your location, web browsing and app usage data to determine whether you fit into an audience Verizon or another company is trying to reach. If you choose to participate in Verizon Selects, you may receive marketing messages, offers and other content that interests you more than what you receive today. We won't share information that identifies you personally with any non-Verizon companies. Sign In For A More Personal Support Experience Forgot Password? Forgot User ID? Register Popular Content Verizon Selects FAQs Video: Verizon Selects Verizon Wireless Privacy Policy Related Support Manage your Verizon Selects preferences in My Verizon Learn about Verizon Smart Rewards Ask the Verizon Wireless CommunitySign In HOW TO USE Back to How to Use Home > Support > Services & Apps > Verizon Selects > How To Use > Verizon Selects Participation Agreement Shop Support My Verizon RESIDENTIAL BUSINESS WIRELESS Set Location Español Store Locator Contact Us Sign In/Register ([KLELW Get Help at a Store Attend a Workshop Attend a free workshop in a store to get detailed and personal assistance from a Verizon expert. Schedule a Workshop Visit a Store Store Locator Visit the Community Forums Ask questions, or share your opinions on Verizon Wireless products and services. Visit the Community Talk to us on Twitter Got something to ask us? We're happy to help. Visit @VZWSupport Connect with us on Facebook Post a support question on our wall and get a response from a Verizon Expert. Visit Verizon Wireless Facebook use of your Verizon voice services and related billing information (also known as Customer Proprietary Network Information or “CPNI”). Other information about your use of Verizon products and services (such as data and calling features and use, FiOS service options, equipment and device types). What are you doing with my information? To make marketing messages more relevant, Verizon will analyze the information described above to identify you as part of a group of people a marketer is trying to reach. Your CPNI and other information will be shared among the Verizon family of companies. You have a right, and Verizon has a duty, under federal law, to protect the confidentiality of your CPNI. We will not share information that identifies you personally with any non- Verizon companies. My choices. You need to “opt in” to be part of Verizon Selects and consent to the use of your data. You will remain a participant until you withdraw your consent. Information Verizon Selects collects while you are a participant may be kept for up to three years. You can discontinue participating or set your preferences at any time by visiting www.vzw.com/VerizonSelects. Not all accounts are eligible to participate in Verizon Selects. For more information, please visit www.verizonwireless.com/SelectsFAQs. If you choose not to participate your choice will not affect any of your other Verizon services. Still Have Questions? 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