Gateway Group, LLC (“GG,” “we,” “our”) is committed to protecting our users’ and visitors’ privacy. This policy explains how we collect, use, share, and disclose personal information about you when you interact with or use our websites, products, and services.
1. Personal Information We Collect
We collect personal information from you (1) when you choose to use, apply for, or register for a GG product and service, (2) when you choose to send an e‐mail, participate in surveys, or engage in other transactions or interactions with GG, or (3) when you visit GG’s websites. Through these interactions we may collect the following personal information:
- Personal Identifiers: Full name, physical address, mailing address, phone number, email address, date of birth, account number, and last four digits of government identification number
- Protected Class Information: Information relating to the customer’s hearing loss, including self-certifications
- Commercial information: User preferences, purchasing history, dates of service, date of last call, and participation in promotional activities
- Internet Data: IP address, device ID, operating or information system, machine type, cookies, and website interactions
- Geolocation Data: Device location enabled services
We also may collect non-identifiable or aggregate information about your use of our GG products and services and our business relationship with you when you interact with or use our GG website, services, or respond to e‐mails, newsletters, or promotional or other informational communications.
2. Purposes for Collecting and Using Personal Information
GG uses the collected personal information for various purposes, including but not limited to the following:
- To initiate or provide GG products and services
- To provide you with customer service and support
- To monitor, analyze, improve and develop our Services and to create and test new Service features
- To determine eligibility for the Services
- To provide a more customized user experience
- For internal marketing and promotional purposes
- To generate anonymized, aggregated data containing only de-identified, non-personal information that we may use for research purposes
- To enforce applicable provisions of GG’s Service and Product Agreements
- To detect, prevent, or otherwise address fraud, identity theft, security, or other technical issues
- To protect the rights, property, or safety of GG, our employees or users, or the public as required or permitted by law
- To comply with legal requirements such as a law, regulation, search warrant, subpoena, or court order
- For any other purpose for which you expressly authorize us to use your information.
3. Disclosure of Personal Information
GG does not rent or sell your Personal Information to third parties. However, we may engage third party service providers to perform tasks on our behalf and need to share your information with them to provide products or services to you. We may also share your information with third parties when necessary to comply with laws and regulations (including government agencies and private entities responsible for overseeing or administering the Telecommunications Relay Fund and verifying eligibility for GG services); respond to subpoenas and court orders; exercise our legal rights or defend against legal claims; investigate, prevent, or take action regarding illegal activities, suspected fraud, potential threats to our property or the physical safety of any person, or violations of our usage instructions and applicable terms and conditions; facilitate the financing or insuring of our business or a disposition or sale of all or part of our business or assets, or as otherwise permitted or required by law.
As indicated above, pursuant to State regulations we may disclose certain information, including personal information, to authorized companies or independent contractors (“authorized third parties”) in order to: (1) provide you with video products and services; (2) install, maintain and repair our products and services; (3) offer you additional video features and services of the type you already registered for with GG; or (4) process information on our behalf. These authorized third parties have agreed to certain confidentiality protections.
5. Analytics and Advertising Information
We work with partners, including Google Analytics and Facebook Business Services, that provide us with certain analytics and advertising services. These partners collect certain information to help us understand how you and others interact with our website, serve advertisements on our behalf on different internet platforms, and measure the performance of those advertisements. They may do so through cookies and similar tools used to collect internet or other electronic network activity information (e.g., IP addresses, access times, or pages visited). You can control or limit the collection of your information through these tools by changing the settings on your browser or device, as specified above in Section 5. [You can find out more information about Google Analytics cookies here and how to prevent the use of Google Analytics relating to the use or our website by downloading and installing the browser plug-in available here. You can also control which ads you receive on Facebook through your Facebook settings, available here.]
6. Links to Other Website
7. Reasonable Security Measures
GG will take reasonable steps and use security measures appropriate to the nature of the information at issue and that comply with applicable laws to protect customers’ personal information against unauthorized access and exfiltration, acquisition, theft, or disclosure. Given the nature of information security, there is no guarantee that such safeguards always will be successful.
8. Opt-Out Right and Access to and Ability to Correct Personal Information
Visitors may opt out of having their personal information collected by GG disclosed to third parties, or used by GG or third parties to send promotional correspondences to the visitor, by contacting GG via postal mail, email at the addresses below, or telephone 605-370-6598. Upon request via postal mail, email, or phone, GG will provide to visitors a summary of any personal information retained by GG regarding the visitor. Visitors may modify, correct, change or update their personal record or cause their personal record to be removed from GG’s database. GG will only send personal records to the email address on file for the visitor name associated with it. Visitors may also submit request to opt-out via postal mail at: Gateway Group, 102 N. Krohn Place, Suite 100, Sioux Falls, SD 57106 Attn: Customer Care or email at firstname.lastname@example.org
9. Collection of Personal Information from Children
GG does not knowingly solicit or collect personal information from individuals under the age of 18 without parental consent. If you are under the age of 18, you are not authorized to register for GG’s services, or submit any other information to us, via our website.
If you are the parent or guardian of a deaf or hard of hearing child under the age of 18 who wishes to use GG’s products or services, you may register on behalf of your child via our website. After you provide the required registration information, you will receive an email with information regarding your child’s registration. The email will provide instructions for how to verify that you have provided registration information on behalf of your child and that you consent to the collection of certain personal information from your child.
As described further in the email, to provide such verification and consent, you must participate in a live videoconference with GG Customer Care. You will be required to provide a government-issued photo identification to identify yourself. The email will also provide instructions for how you can delete your child’s registration profile, if you would like.
GG will not condition your child’s use of GG’s products and services on your consent to data collection beyond what is reasonably necessary for GG to provide its products and services to your child. GG’s products and services do not allow children to make their personal information publicly available.
GG may use personal information that it collects from your child to provide video relay service support and to allow your child to use our services, such as completing and receiving calls and maintaining a contact list. GG may also use personal information it collects from your child in connection with federal or other legal requirements, such as responding to a subpoena or court order, providing information as required by State regulations, or providing information for purposes of emergency communications.
You have the right to ask GG to allow you to review information GG has collected about your child, to stop collecting personal information about your minor child, or to delete information it has on file about your minor child at any time. You may exercise these rights by contacting GG Customer Care at 605-370-6598. GG will comply with your request within a reasonable time.
10. GG’s Right to Contact Users
12. Contact Information
If you have any questions about this policy, you may contact us via email at email@example.com or via regular mail to the attention of Customer Care, Gateway Group, 102 N. Krohn Place, Suite 100, Sioux Falls, SD 57106.