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Privacy Policy

Last updated December 20, 2019

Hamilton Relay, Inc. (“we” or “us”) is committed to protecting the privacy of our customers. This privacy policy is designed to inform you about how we treat the information of customers of the various Telecommunications Relay Services we offer, as well as how we treat information obtained through the Hamilton Relay website and mobile apps.

What Information We Collect and How We Collect It

We may collect information about you and your use of our products and services, as well as about how you use our website and mobile apps. The types of information we collect about you include:

  • Identifiers including names, postal addresses, email addresses, telephone numbers, IP addresses, device identifiers, and, for certain relay users, the last four digits of social security numbers;
  • Commercial information, including records of services used; and
  • Internet or other electronic network activity information, including browsing history.

We collect this information in the following ways:

When You Provide Personal Information to Us

We collect information about you that you provide to us, such as your name and contact information, including when you provide it to us through our website or mobile apps. In order to register for relay services for which the Federal Communications Commission (“FCC”) requires registration, we will ask you to provide certain information to us, including your name, your date of birth, the last four digits of your social security number (or equivalent, if applicable), your address, your telephone number, and your registered location information for emergency calling purposes. We may also maintain information provided by you, including your address and telephone number, in connection with call handling preferences as contained in your profile. FCC rules require that in certain cases we collect and maintain records of self-certification from you, or third party certifications from approved hearing health professionals, about your eligibility to use certain relay services.

When You Use Our Services

We collect information about how you use our relay services. This information includes customer proprietary network information (“CPNI”), which includes information such as the type and quantity of the services to which you subscribe; the equipment and facilities used; and the numbers, dates, times, and duration of the calls you place. As noted below, FCC rules provide you certain rights with respect to access, use, and disclosure of your individually identifiable CPNI.

When You Visit Our Website and Mobile Apps

We collect certain information about your computer or device when you visit our website or mobile apps, such as the domain name, browser, type of computer operating system, information about the web page from which the visitor linked to the site, and time spent on different pages within the site or app. We may use cookies and other tracking mechanisms to collect information about how you use our website and apps. A cookie is a small data string that our server requests that your browser store and that contains a unique user ID. Cookies are used to deliver web content specific to your interests. The cookie permits the server to recall information from your previous visit. With most web browsers, you can choose to change your settings to disable cookies. You may also decline Internet cookies by using the appropriate feature of your web client software. Please be aware, however, that cookies may be required to complete certain functions on the Hamilton Relay website and other Internet sites.

Our website also uses Google Analytics, a web analytics service provided by Google, Inc., that collects information about how visitors use our website. Google Analytics places a cookie on your web browser to identify you as a unique user and only Google can use the cookie. Google Analytics collects information only regarding the domain/IP address, or device identifier, of visitors to the sites. It does not collect your name or other similar information and we do not combine the information collected through Google Analytics with any other personal information we have about you. The Google Analytics Terms of Use and the Google Privacy Policy restrict Google’s ability to use and share information collected by Google Analytics about visitors to the sites. You can prevent Google Analytics from recognizing your return visits to sites by disabling cookies on your browser or by installing the Google Analytics browser add-on.

Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the website or online service that a user visits, indicating that the user does not wish to be tracked. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to those signals. For more information regarding Do Not Track mechanisms, see http://allaboutdnt.com/.

From Third Parties

At times, we receive information about customers and prospective customers from third parties. For example, we may acquire mailing lists or lists of participants of conferences we sponsor. We also may collect information about you through online platforms, including social media platforms (e.g., when you engage with us through social media). Finally, we receive information from our business partners without whose services your service and your CapTel device would not properly function.

How We Use and Share the Information We Collect

We use the personal information that we collect to provide our services, to improve our services, and to market the most helpful and targeted products and services to you in order to meet your needs as permitted by applicable law.

We, at times, disclose information about you and how you use our services, and do so for several purposes. The types of information we disclose include: 

  • Identifiers including names, postal addresses, email addresses, telephone numbers, IP addresses, device identifiers, and, for certain relay users, the last four digits of social security numbers;
  • Commercial information, including records of services used; and
  • Internet or other electronic network activity information, including browsing history.

We share this information for the following purposes:

As Required by FCC Regulations

We are required to share your information by FCC regulations in the following contexts:

When You Make a 911 Call

We will provide your registered location information and other information to an emergency service provider when you make a 911 call.

For Inclusion in the TRS User Registration Database

When you use our service, you understand and consent to the transmittal of the following information to the TRS User Registration Database to ensure proper administration of the TRS program:

  • full name;
  • full residential address;
  • telephone number;
  • a unique identifier such as the electronic serial number of your IP CTS device, your log-in identification, or your email address;
  • the last four digits of your social security number or Tribal Identification number (or alternative documentation, as permitted by the FCC);
  • your date of birth;
  • your registered location, if applicable;
  • that we provide you service;
  • the date your service was initiated and, when applicable, terminated;
  • a digital copy of your self-certification of eligibility for IP CTS and the date we obtained it; and
  • if you are an existing user, the date on which you last placed an IP CTS call.

You understand that the failure to allow us to transmit this information to the TRS User Registration Database will result in being denied service.

For Regulatory Purposes

We must provide certain information about you and your service usage to the Administrator of the TRS Fund and/or the FCC for billing purposes or to respond to a customer complaint.

With Our Partners and Service Providers

We may share this information with partners and certain service providers that help us deliver and market the services that we provide to consumers. When we share information in this manner, we contractually limit the use and disclosure of the information we share for the specific purpose for which we shared it.

Please also note that by using our services, you also engage and intentionally interact with CapTel, Inc., without whose services your service and your CapTel device would not properly function. Thus, you direct us to disclose your personal information to CapTel, Inc. in connection with its provision of services to you. CapTel, Inc. uses your personal information according to its privacy policy, and you understand that we do not control and are not responsible for its policies.

For Other Legal, Safety, and Fraud Prevention Purposes

We also may share your information (1) as otherwise required by law, including pursuant to a duly-served subpoena or other government request for information; (2) to investigate or defend against third-party claims or allegations; or (3) to protect our rights, property, and personal safety, or that of our customers or others.

Among Our Affiliated Companies or as Part of a Transaction

We also may share your information with one of our affiliated and commonly-branded companies; or as part of any merger, acquisition, sale of company assets or transition of service to another provider.

We do not otherwise share our customers’ personal information and never will sell your personal information. We may, however, share anonymous or aggregate information with third parties for purposes that include improving how we provide service to existing and potential customers.

How We Protect Your Information

We use reasonable technical, administrative, and physical safeguards to protect the personal information we collect. Notwithstanding these efforts, we cannot guarantee that we can prevent every unauthorized attempt to access, use, or disclose customer information. We also cannot guarantee the confidentiality of any communication or information you provide.

We retain the personal information we collect only as long as we deem reasonably necessary for business, accounting, tax, legal or regulatory purposes.

Your Privacy Choices

We offer several choices regarding how we use and share your information.

CPNI

You can limit our use and sharing of your individually identifiable CPNI to market relay-related services to you. To limit our use and sharing of your individually identifiable CPNI, please contact us by phone or email.

Telephone and Mail Solicitation

You can also opt out of receiving telephone or mail solicitation from us. To request removal from our solicitation lists, please contact us by phone, email, or letter.

Updating Your Information

We encourage you to contact us to modify, correct, or update your information. In order to make such a request, please email us.

California Residents

California law permits California residents to make certain requests of us regarding the personal information we have about them. Specifically, California law provides residents with the right to request that we disclose what personal information we collect, use, and disclose about them. If you are a California resident, please visit Your California Privacy Rights to learn more about your rights under California law and how to exercise them.

Social Media

We may post photos taken during community and corporate events to a Hamilton Facebook page or other internet page. As a general rule, we will not tag or otherwise identify individuals in photos unless those individuals have agreed to be identified. However, if you would like a photo removed from a social media post that we control, please send an email to info@hamiltonrelay.com. Please include in the email a link to where the photo is posted, your name, contact information, the title of the image the you wish to have removed, and the reason the you would like it to be removed.

Children’s Privacy

We do not knowingly collect personal information from individuals under the age of 18 without their parent’s or guardian’s verifiable consent. If registration is required for any services on our website or mobile apps, and a user submits information indicating he/she is a child, the child’s parent or guardian will receive an email alerting them to such registration and provide instructions on how they can provide verifiable parental consent. If we do not receive verifiable parental consent within a reasonable time, we will delete the child’s registration. We do not knowingly provide any personal information collected about children, regardless of its source, to any third party for any purpose whatsoever. In addition, we do not use information collected through the website or mobile apps from users self-identified as children for any marketing or promotional purposes whatsoever, either inside or outside Hamilton Relay.

Links to Third-Party Websites and Content

We are not responsible for content or privacy policies of other third party websites. We encourage you to review the privacy policies of such websites.

Updates to this Privacy Policy

We constantly strive to improve the services we offer and may consequently update this privacy statement from time to time. We reserve the right to expand our capabilities for information collection and use and may change policies along with this privacy statement at any time. We also reserve the right to contact site visitors regarding account status and changes to the subscriber agreement, privacy policy, or any other policies or agreements relevant to site visitors.

Contacting Us

To learn more information about our information practices or exercise your rights under this privacy policy, please contact us:

By Phone: 800-618-4781
By Email: info@hamiltonrelay.com