Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully, as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request. We may update and make changes to this policy, so we encourage you to review it periodically.
We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals within our service area, we are subject to the Colorado Privacy Act (CPA), Nebraska Data Privacy Act, and other state and federal laws, including the Children’s Online Privacy Protection Act (COPPA). In developing and maintaining this policy, we have selected the state’s most stringent requirements within our service area in order to better serve and protect our customers.
While a website can be accessed from areas outside of our service area, and anywhere in the world, we and our third parties that manage our website have implemented Global Privacy Controls, together with the ability to opt out of any data collection measures.
- Key Terms. It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Viaero Wireless |
| Personal information | Any information relating to an identified or identifiable individual |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sexual orientation. |
| Sensitive Personal Information | Personal information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status |
| Biometric Information | An individual’s physiological, biological, or behavioral characteristics, including information about an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information |
- Personal Information We Collect About You. We may collect information to provide goods and/or services to you, to help improve your customer experience, and to support our business functions. We may collect the following categories of consumer personal data:
- Identifiers and Personal Information: Information that identifies, relates to, describes, or is capable of being associated with, a particular individual such as name, signature, social security number, address, telephone number, driver’s license, passport number, and state identification card number.
- Payment Information: Account numbers, credit or debit card numbers.
- Commercial information: Purchase and transaction history.
- Biometric information: Fingerprints, voice prints, facial geometry, and retina scans.
- Internet or other electronic network activity information: Mobile device and online identifiers, MAC address, IP address, cookie IDs, browser activity, search history, social media information, and information regarding your interaction with our website or mobile application.
- Audio, electronic, visual, thermal, olfactory, or similar information such as [security video footage and customer service call recordings
- Precise geolocation data: Data about the location of your device.
- Demographic Information: Age, gender, race, citizenship, ethnicity, date of birth, family or marital status, household income, education, professional and employment information.
- Profile Information: Any form of automated process performed on personal data to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual’s economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
- Sensitive Data: Data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation or citizenship or immigration status; the processing of genetic or biometric data for the purpose of uniquely identifying an individual; personal data collected from a known child; or precise geolocation data. We will not process your sensitive data or personal data collected from a known child without obtaining your consent.
- How Your Personal Information is Collected. We collect personal information from the following categories of sources:
- From you, directly, whether in person, by telephone, text, email, and/or via our website
- Third party with your consent (e.g., your bank)
- Automated means through your use of your mobile device or other technology, such as when you visit our websites or use our mobile applications or services, or click on advertisements or links in emails you receive from us
- Advertising networks
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platforms
- Social networks
- Data brokers
- Publicly accessible sources (e.g., property records)
- Cookies on our website
- Our IT and security systems include:
- Door entry systems and reception logs
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems.
- Use of Computer Tracking and Web Beacon Technologies.
- No Tracking of Personal Information.
- Viaero’s website is not set up to track, collect or distribute personal information not entered by visitors. Through website access logs Viaero may collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our sites. This information is used for internal purposes by technical support staff for research and development, user analysis and business decision making, all of which provide better services to the public. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties.
- Viaero may also use a Web beacon or other technologies to tailor its website(s) to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Website, a non-identifiable notice of that visit is generated which may be processed by Viaero or by its suppliers. Web beacons usually work in conjunction with cookies. If a customer does not want cookie information to be associated with customer’s visits to these pages, a customer can set its browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
- Collection of Non-Identifiable Information.
- Viaero may collect non-identifiable information from user visits to the Viaero website(s) in order to provide better customer service. Examples of such collecting include traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on the website(s); website and system administration; user analysis; and business decision making. Such information is sometimes known as “clickstream data.” Viaero or its contractors may use this data to analyze trends and statistics.
- Collection of Personal Information.
- Viaero may collect personal identifying information from a customer during a transaction. Viaero may extract some personally identifying information about that transaction in a non-identifiable format and combine it with other non-identifiable information, such as clickstream data. This information is used and analyzed only at an aggregate level (not at an individual level) to help Viaero understand trends and patterns. This information is not reviewed at an individual level.
- How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:
- No Tracking of Personal Information.
- To comply with our legal and regulatory obligations
- For the performance of our contract with you or to take steps at your request before entering into a contract
- For our legitimate interests or those of a third party –or–
- Where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
| To provide products and/or services to you |
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| To prevent and detect fraud against you or the Company | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business |
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| Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training, and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information |
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| Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorized access and modifications to systems |
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| Updating and enhancing customer records |
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| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments |
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Marketing our services to:
| For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers |
| Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services |
| External audits and quality checks |
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- Promotional Communications. We may use your personal information to send you updates by email, text message, telephone, or post about our products and/or services, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”).
We will always treat your personal information with the utmost respect and never sell it to other organizations outside the Company for marketing purposes.
You have the right to opt-out of receiving promotional communications at any time by:
- Contact us at customerservice@viaero.com or by calling customer care at 877-484-2376.
- Using the “unsubscribe” link in emails or “STOP” number in texts or
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
- Who We Share Your Personal Information With. We routinely share personal information with:
- Our affiliates, including companies within the Viaero group.
- Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses, and delivery companies
- Other third parties we use to help us run our business, such as marketing agencies or website hosts
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
- Credit reporting agencies
- Our insurers and brokers
- Our banking institution[s]
- Law enforcement and other government agencies and regulatory bodies to comply with our legal and regulatory obligations.
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We will not sell your personal information to any third party.
- Categories of Information Disclosed for a Business Purpose.
In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose with the following categories of third parties:
| Categories of Third Parties and Business Purpose for Disclosure | Categories of Personal Information |
| • Our affiliates, including companies within the Viaero group; • Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses, and delivery companies; • Other third parties we use to help us run our business, such as marketing agencies or website hosts; • Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers; • Credit reporting agencies; • Our insurers and brokers; • Our bank(s); • External auditors | • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. • Personal information such as a name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, other financial information, medical information, health insurance information. • Characteristics of protected classifications under State or federal law such as race, religion, national origin, age, sex, sexual orientation, pregnancy, familial status, disability, military or veteran status, and genetic information. • Commercial information such as purchase or transaction history. • Biometric information such as voice prints, fingerprints, imagery of the iris or retina, and face geometry. • Internet or other electronic network activity information such as browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement. • Geolocation data. • Audio, electronic, visual, thermal, olfactory, or similar information such as security video footage and customer service call recordings. • Professional or employment-related information. • Education information. • Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. • Sensitive personal information such as social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; race, ethnicity, and citizenship or immigration status, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; biometric and health information; information regarding a consumer’s sex life or sexual orientation. |
- Use or Disclosure of Sensitive Personal Information. We do not use or disclose your sensitive personal information for purposes other than those listed below:
- The use that is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information
- To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions
- To ensure the physical safety of natural persons
- For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business
- To perform services on behalf of the business
- To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business
- To collect or process sensitive personal information where the collection or processing is not for the purpose of inferring characteristics about a consumer
You have the right to limit the use and disclosure of your sensitive personal information. If you exercise your right to limit the use of your sensitive personal information, we will limit our use and disclosure of your sensitive personal information for the purposes listed above.
- How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf
- To show that we treated you fairly –or–
- To keep records required by law
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
- Your Rights Under this Privacy Policy and Applicable Statutes and How to Exercise Them.
Residents of Colorado have certain personal data rights under the Colorado Privacy Act (CPA).
You have the right to:
- Opt-out of the processing of your personal data for purposes of:
- Targeted advertising
- Sale of personal data
- Profiling that produces legal or significant effects on you
- Access your data and confirm that your data is being processed by us.
- Request deletion of your data held by us.
- Request correction of your data held by us.
- Receive your requested data in a usable and transferable form.
- Non-discrimination or retaliation for exercising any of these rights.
- Designate an agent to exercise your rights on your behalf.
- Appeal if your request is denied.
- Opt-out of the processing of your personal data for purposes of:
Responding to Requests. We are required to respond without undue delay but within 45 days of receipt of your request. Depending on factors such as the type and complexity of the request, we may extend the time for response once by 45 additional days, as long as we notify you within the original 45 days.
If we decline to act regarding your request, we must notify you without undue delay, but within 45 days of receipt of the notice and provide information on our appeal process. We are required to provide justification and provide information on the appeal process within a reasonable time after the communication of the decision to decline.
You can request information under this Privacy Policy free of charge up to twice per year. For additional or subsequent request within a 12-month period, we may charge an amount that is the same for the provision of a public record, which is $0.25 per standard page, or a fee not to exceed the actual cost of providing a copy, printout, or photograph of the record in a format other than a standard page.
How to Exercise Your Rights: If you would like to access your data, confirm that your data is being processed by us, request deletion of your data, request correction of your data, or receive your requested data in a usable and transferable form, you can contact us at customerservice@viaero.com or by calling customer care at 877-484-2376.
- Designated Agent. If you wish to designate an agent to exercise your rights on your behalf or are a guardian or conservator exercising consumer rights on behalf of another you can designate an authorized account representative. You may contact us at customerservice@viaero.com or by calling customer care at 877-484-2376 to complete this request.
- Data Requests. Please note that you may only make a data access or data portability disclosure request twice within a 12-month period. Subsequent requests may result in fees as noted above.
If you choose to contact us directly by email at customerservice@viaero.com or by calling customer care at 877-484-2376, and please be prepared to provide the following:
- Enough information to identify you (e.g., your full name, address and customer or account reference number, PIN number);
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.
Any personal data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
- Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Changes to This Privacy Notice. We may change this privacy notice from time to time on our website or through other means of contact such as email to our customers.