Frontier Communications Privacy Policy for Connecticut and Texas Residents

This Privacy Policy supplements the information contained in the Frontier Communications Privacy Policy and describes how Frontier Communications Parent, Inc., and its subsidiaries that provide or support the provision of services in Connecticut and Texas (collectively, “Frontier,” “we,” or “us”) collect, use, and disclose personal data about Connecticut and Texas residents (“you”) subject to additional protections under the Connecticut Data Privacy Act (“CTDPA”) and the Texas Data Privacy and Security Act (“TDPSA”). Personal data means any information that is linked or reasonably linkable to an identified or identifiable individual. This Privacy Policy applies to personal data we collect online and offline, such as when you use our website and mobile app; we provide, manage, and improve the services we offer; we bill and collect for our services; we deliver relevant advertising; we respond to customer questions and concerns; we conduct interviews and surveys; and we manage, repair, and protect our network (collectively, our “Services”).

We may provide different or additional notices of our privacy practices with respect to other personal data collection practices not within the scope of this Privacy Policy, in which case this Privacy Policy will not apply.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the bottom of this Privacy Policy. We may also provide you with an additional notice (such as by adding a statement to the Services or sending you a notification), in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

I. NOTICE AT COLLECTION

This Notice at Collection describes how we collect, use and disclose personal data.

A. Collection of Personal Data

1. Personal Data You Provide to Us

We collect personal data you provide directly to us. For example, we collect personal data directly from you when you use our Services. The types of personal data that we may collect directly from you include the following:

• Contact Information: We collect certain identifiers and contact information from you, such as name, phone number, email address, postal address, and other similar identifiers.
• Financial and Transactional Information: We collect payment and other financial information, and information regarding the services you purchased and your purchasing histories.

2. Personal Data We Collect Automatically

We automatically collect certain personal data about your interactions with us or our Services, including:

• Activity Information: We collect information about your activity on our Services, such as network usage, browsing history, search history, and information regarding your interaction with a website, application, or advertisements.
• Call Information: When you contact us or we contact you, we may monitor or record the communication, and keep records of and about the communication, so that we can provide better service. We will inform you during such a call that the call may be monitored or recorded.
• Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, bandwidth usage, speed test results, modem/gateway/set top box IDs, configuration files, and performance data. We also collect your TV and other video viewership, including movie rental, digital video recorder activity, and purchase data.
• Information Collected by Cookies and Similar Tracking Technologies: We and others that control collection of personal data use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. We also may receive demographic information about you, or information regarding your interests. Our use of certain types of cookies and tracking technology may constitute processing or selling of personal data for targeted advertising purposes under the CTDPA and the TDPSA. To opt-out of the selling or processing of your personal data for targeted advertising purposes, see Your Connecticut and Texas Rights in Section II below.

3. Personal Data We Collect from Other Sources

We obtain information from other sources. For example, we may collect information from credit reporting agencies, advertising networks, data analytics providers, operating systems and platforms, mailing list providers, social networks, and other advertising partners. This information includes your contact information and usage data collected through cookies and other trackers. In addition, we may obtain information from other providers we partner with to provide you services, such as Wi-Fi router systems, email platforms, computer protection systems and video services.

4. Personal Data We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

B. Purpose and Use of Personal Data

We may use the categories of personal data identified in Collection of Personal Data in Section I.A above for the following purposes:

• Provide, maintain, and improve our Services;
• Process transactions and send you related information, including confirmations, service terms, service bills, customer experience surveys, and other notices;
• Personalize and improve your experience on our Services;
• Send you technical notices, service and security alerts, and support and administrative messages;
• Respond to your comments and questions and provide customer service;
• Communicate with you about products, services, and events offered by Frontier and others and provide news and information that we think will interest you;
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Personalize the advertisements you see on third-party platforms and websites;
• Personalize the advertisements you see when you use our Services based on information provided by our advertising partners;
• Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Frontier and others;
• Debug to identify and repair changes, interruptions, and errors in our Services;
• Comply with our legal, regulatory and financial obligations; and
• Carry out any other purpose described to you at the time the information was collected.

C. Disclosure of Personal Data

We may disclose each of the categories of personal data identified in Collection of Personal Data in Section I.A above to the following other parties in the following circumstances or as otherwise described in this Privacy Policy:

• Our Vendors which may be considered Processors under the CTDPA and the TDPSA: We may disclose personal data to processors who provide us services, such as IT, system, security and network administration, marketing and professional advisory and support services. In addition, we may disclose and request information to other providers we partner with to provide you services, such as Wi-Fi router systems, email platforms, computer protection systems and video services.
• Processed for Targeted Advertising: We may use, disclose or process personal data, which may be considered selling personal data under the CTDPA and the TDPSA for targeted advertising purposes, as described in Processing of Personal Data for Targeted Advertising in Section II.A below.
• Legal Disclosures: We may disclose personal data if we believe that disclosure is in accordance with, or required by, any applicable law, regulatory or legal process, including lawful requests by public authorities to meet national security, regulatory or law enforcement requirements. We may also disclose personal data if we believe that your actions are inconsistent with our user terms, agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Frontier, our users, the public, or others.
• Disclosed to Advisors: We may disclose personal data with our professional advisors where necessary to obtain advice or otherwise improve, protect and manage our business interests.
• Disclosed During Change of Ownership: We may disclose personal data in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Among Our Family of Companies: Personal data may be disclosed between and among Frontier and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
• With Your Consent: We may disclose personal data with your consent or at your direction.
• Disclosure of Non-Personal Data: We may also disclose aggregated or de-identified information that cannot reasonably be used to identify you.

D. Retention of Personal Data

We store personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, tax, regulatory, or other compliance obligations.

II. YOUR CONNECTICUT AND TEXAS RIGHTS

The CTDPA and the TDPSA afford residents of Connecticut and Texas respectively with certain rights with respect to their personal data. If you are a Connecticut or Texas resident, these rights and disclosures apply to you.

A. Processing of Personal Data for Targeted Advertising

We may process your personal data for targeted advertising purposes. For information about how to exercise the right to opt-out of such processing or sale, see the Instructions on How to Exercise Your Privacy Rights in Section II.E below.

B. Opt-Out Preference Signals

An opt-out preference signal is a signal that is sent by a platform, technology or mechanism on your behalf that communicates your choice to opt-out of the sale or processing for targeted advertisements of your personal data. You can learn more about implementing opt-out preference signals here or by exploring other developing technologies and services that offer this tool.

We treat opt-out preference signals as valid requests to opt-out of the sale or processing of your personal data for targeted advertising under the CTDPA and the TDPSA. Ordinarily, your opt-out preference signal is sufficient for us to honor your request, but in some instances, we may request additional information to help facilitate your request for offline processing. We will not use, disclose or retain this additional information for any purpose other than to facilitate the request.

Please note that you can also opt-out of the sale or processing of your personal data for targeted advertising through our other methods described in the Instructions on How to Exercise Your Privacy Rights in Section II.E below.

C. Sensitive Data

Frontier does not collect other information that would be considered sensitive data under the CTDPA.

D. Your Rights

The CTDPA and the TDPSA afford residents of Connecticut and Texas the following rights with respect to their personal data, subject to certain exceptions:

• (1) Right to Delete. You have the right to request us to delete the personal data we have collected about you.
• (2) Right to Correct. You have the right to request us to correct inaccurate personal data we maintain about you.
• (3) Right to Confirm Processing and Access. You have the right to confirm whether or not we are processing your personal data and to access such personal data, unless such confirmation or access would require us to reveal a trade secret.
• (4) Right to Data Portability. You have the right to receive the information under right (3) in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the personal data to a person without impediment, where the processing is carried out by automated means.
• (5) Right to Opt-Out of Profiling. You have the right to opt out of the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• (6) Rights Related to Selling or Processing of Personal Data for Targeted Advertising. You have the right to opt out of the processing of your personal data for targeted advertising or the sale of your personal data.
• (7) Right to No Discrimination. You have the right not to be discriminated against for exercising any of these rights, including denying goods or services, charging different prices or rates for goods or services or providing a different level or quality of goods or services.
• (8) Right to Appeal. If we decline to take action in response to your exercise of a privacy right, we will inform you of the reason for denying your request and provide you instructions on how to appeal the decision.

E. Instructions on How to Exercise Your Privacy Rights

You may exercise your privacy rights by completing our web form here or emailing us at privacy@FTR.com. In some instances, we will need to verify your identity using commercially reasonable efforts before honoring your privacy right request. We will verify your identity by asking you to provide personal data related to your recent interactions with us. We will honor your privacy rights request within 45 calendar days of receipt, unless we request an extension under the CTDPA or the TDPSA. If you would like to make a request to opt-out of the processing of your personal data for targeted advertising or the sale of your personal data, click on the Do Not Sell or Share My Personal Information link here.

F. Appealing a Denial of a Privacy Right Request

You may appeal a denial of your privacy right requests by completing our web form here or emailing us at privacy@FTR.com. Within 60 days of receipt of an appeal, we will inform you in writing of any action taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may submit a complaint to the Connecticut Attorney General at  https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page if you are a Connecticut resident, or to the Texas Attorney General at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint if you are a Texas resident.

G. Authorized Agents

You may exercise your privacy rights through an authorized agent. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please Contact Us in Section III below.

III. CONTACT US

If you have any questions about this Privacy Policy, please contact us at  privacy@FTR.com or Frontier, P.O. Box 9608, New Haven, CT 06535.

Last Updated and Effective Date: July 1, 2024